Modern Slavery Act Statement – 2017/2018

Aspire Defence Services Limited (ADSL) is a company formed originally by Carillion Plc and Kellogg Brown & Root Limited ( “KBRL”) , and now wholly owned by KBR, to deliver services on the UK MoD’s Project Allenby Connaught ( the “Project”), being a 35 year Project to finance, design, build and maintain living accommodation and associated infrastructure for troops across Salisbury Plain and Aldershot. The Company provides a broad range of services covering facilities management for the Project and contracts for other customers, all activities delivered through a combination of self-delivery and sub-contract support. It employs over 960 staff.

ADSL recognises that modern slavery, which includes human trafficking, is a horrific crime that fundamentally violates human rights, and which sadly remains an important issue that has no place in society. The organisation is therefore fully committed to meeting its obligations under the Modern Slavery Act 2015 and related Government guidance. Responsibility for compliance is vested in ADSL’s Senior Leadership Team reporting through the Audit Committee to the Board of Directors.

During 2017, ADSL has taken the following steps to support the strategic intention to eliminate any risk of Modern Slavery offences being committed by ADSL and its supply chain:

• We have established a Modern Slavery Act policy and reflected it on our Management System .
• We have provided information and guidance to our staff, including a presentation to staff to promote awareness and outline our Modern Slavery Act policy and related procedures established to support this.
• We have contacted all our Supply Chain to confirm that those whose turnover so requires have generated the statements necessary to evidence compliance with the Modern Slavery Act legislation, and we are implementing changes to our subcontracts to specifically reference the Act and the need to comply with it.
• We conduct rigorous due diligence on suppliers. Before introducing a new supplier, we undertake a thorough qualification exercise in which we assess business suitability and technical expertise for the work they would be engaged to perform. As part of this process we require all suppliers to sign up to a Supply Chain Code of Ethics, requiring them to evidence their commitment to ethical behaviour. Following appointment, we are robust in our management of Suppliers.
• Concerning recruitment, our policy is to vet all staff to ensure their suitability to work for ADSL. In practice, this process also involves security clearance which provides some further protection against Modern Slavery abuses.
• Our staff management procedures are mature, involving regular reviews and ‘grandparent’ reviews to offer further protection to our staff. In addition, we operate a well-publicised Whistleblowing ‘hotline’, providing staff with the facility to raise any concerns to a trained, independent professional with an escalation path to the Whistleblowing committee reporting to the Board through the Audit Committee.

Notwithstanding the controls framework outlined above we are committed to enhancing processes, procedures and general awareness about this subject to further strengthen our approach. During 2018 we will continue to develop our procedures, promote awareness and continue to demonstrate commitment to the objectives of the legislation and assess those responses. We will also provide further information to our staff to promote greater personal engagement in the drive to eradicate Modern Slavery and encourage staff to raise any concerns with senior management or through the Whistleblowing line.

This statement is made in accordance with the requirements of Section 54 of the Modern Slavery Act 2015 and constitutes ADSL’s Modern Slavery Act statement for the year ended 31 December 2017.

Bob Kerry

Board Director & Chairman

August 2018