Modern Slavery Statement
Modern Slavery and Human Trafficking Statement for the financial year ended 31 December 2021
This statement is made by John Laing Group Limited (“John Laing”) pursuant to Section 54 of the Modern Slavery Act 2015 and applies to all of John Laing’s subsidiaries whether incorporated within or outside the UK. It has been approved by the John Laing Board of Directors.
We will report each year on a number of matters such as policy, training, and due diligence processes taken to combat slavery and trafficking, to drive transparency and promote ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking.
John Laing is a leading international investor in core infrastructure projects and businesses. We are a long-term and responsible investor with a strategy focused on developing and delivering core infrastructure in OECD countries.
Our business is focused on two investment areas:
• PPP & Projects: developing and delivering PPP and other concession-based projects, as well as similar core infrastructure projects; and
• Mid-market Infrastructure: investing in low-risk mid-market infrastructure assets and businesses.
John Laing invests across the spectrum of development, under construction, and operational assets. We invest across a broad range of sectors, including transportation, energy and utilities, telecommunications and social infrastructure. John Laing has an experienced team of investors and asset managers operating across eight offices covering the UK & Europe, North America, Australia and Colombia. Our local presence and partner relationships enables us to better originate, execute, manage, and create a positive impact for our investments.
We are also signatories to the UN Principles for Responsible Investment (PRI).
Work on modern slavery is a part of our ongoing risk management approach to support human rights. The risk of modern slavery within our direct business operations is considered to be low, however John Laing recognises that it can be indirectly exposed to these risks, for example through its supply chain or project relationships.
Modern Slavery and Human Trafficking
The terms “modern slavery” and “human trafficking” have been used as umbrella terms for the acts of recruiting, harbouring, transporting, providing, or obtaining a person for compelled labour or commercial sex acts through the use of force, fraud, or coercion. “Forced or compulsory labour” is defined in Article 2, International Labour Organisation Forced Labour Convention 1930, and “trafficking in persons” is defined in Article 3 of the Protocol to Prevent, Suppress and Punish Trafficking in Persons, Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime (the Palermo Protocol).
John Laing recognises that modern slavery is a crime and contrary to fundamental human rights; it is both the business imperative and the moral obligation to carry out its activities in a socially responsible and environmentally sustainable manner, with due consideration given to these human rights. Building on our long history of social awareness and community involvement, John Laing’s aim is to contribute to a sustainable future through our employees, investments, services and business conduct.
The Board of John Laing is responsible for matters of corporate responsibility, including the issues of modern slavery and human trafficking. The Board and its Committees review our policies and practices and address any issues which arise. We also have a governance framework which includes a number of executive committees, including the Portfolio Review & Valuations Committee, which is responsible for maintaining the project controls compliance framework to ensure that potential new investments and associated partners are screened and subject to appropriate due diligence in relation to their approach to labour and working conditions.
We also have a Whistleblowing Policy, and a structured mechanism for individuals to report any wrongdoing, or unethical behaviour, which
includes an independent whistleblowing hotline. The Board is made aware of any allegations raised under the Whistleblowing Policy.
The John Laing Group, including the projects and businesses in which we invest, has a large number of suppliers across the jurisdictions in which we operate. As an investor and asset manager, we believe the risk of modern slavery or human trafficking in our supply chains and procurement processes to be low. Helping to ensure we are not indirectly exposed, all new suppliers to John Laing Group, are asked to confirm that their organisation will comply (and take all possible steps to ensure that all their suppliers and subcontractors also comply) with all applicable laws, statutes and regulations related to “forced or compulsory labour”, and that they will not engage (and will take all possible steps to ensure that their suppliers and subcontractors will not engage) in any activity, practice or conduct that would constitute modern slavery. Similar requests are made of the parties involved when we invest in or bid for new projects.
John Laing is committed to transparency and promoting ethical principles and practices related to the prevention of the exploitation and abuse associated with modern slavery and human trafficking. All UK based companies in which we invest with an annual turnover in excess of £36m are required to prepare a Slavery and Human Trafficking Statement.
Monitoring and Review
We will continue to monitor our supply chain and investment portfolio in relation to slavery and human trafficking via our control mechanisms.
We provide training to those members of staff who manage supplier relationships or manage any businesses where we consider there to be a risk of slavery.
The John Laing Board of Directors is committed to implementing and enforcing systems and controls to safeguard against modern slavery, human trafficking and harmful working practices.
Chief Strategy and Operations Officer