Modern Slavery Statement

Rhomberg Sersa Rail Group UK is a full railway engineering service provider specialising in design and construction of concrete slab track solutions, track renewal and maintenance, tunnels, stations, consultancy planning and design. We are part of the Rhomberg Sersa Rail Group (hereinafter referred to as Rhomberg Sersa) with the head office in Bregenz, Austria. The group has a total of 2132 members of staff operating across Austria, Germany, Switzerland, United Kingdom, Ireland, Australia, and Canada.

Rhomberg Sersa has achieved a reputation as being a reliable and fair partner. These values are the foundation of its company philosophy and make Rhomberg Sersa a renowned international family enterprise. In June 2012 Rhomberg Sersa became one of the first companies in Austria to be awarded the Certificate of Ethical Company Management by ÖeGNI.

Rhomberg Sersa is committed to opposing modern slavery in all its forms and taking steps to prevent it from occurring. A zero-tolerance attitude to modern slavery is expected from all employees working for and on behalf of Rhomberg Sersa and all companies and organisations that we work with.

Rhomberg Sersa has created a ‘Compliance Guideline’ which acts as a beacon for ethical and moral behaviour and integrity – not just within Rhomberg Sersa, but also when dealing with partners, suppliers, and competitors

Rhomberg Sersa is committed to acting ethically and with integrity in all business dealings and relationships. This principle is anchored in the Rhomberg Sersa Code of Conduct and is valid worldwide for all affiliated companies.

An essential part of Rhomberg Sersa Rail Group UK’s success depends on our supply chain partners for the procurement of goods and services such as construction material, skilled labour, construction plant and subcontract services.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Policy, Human Rights Policy, and Sustainable Procurement Policy reflect our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. Our policies underpin the Rhomberg Sersa Code of Conduct and Compliance Rules.

As part of our initiative to identify and mitigate risk we have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

We have zero tolerance to slavery and human trafficking. To ensure the same high standards from all our contractors, suppliers and other business partners, all suppliers are fully vetted prior to becoming an approved supplier. Where applicable and appropriate we include specific prohibitions in all our contracting processes against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, which includes adherence and our right to audit routinely or at times of suspicion. We conduct risk assessments to identify areas of risk and engage with our suppliers to ensure modern slavery is not occurring in their business or supply chains.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. In October 2019, we launched mandatory companywide modern slavery training. This training is designed to provide all our employees with basic knowledge of what modern slavery is, the warning signs to look out for and how to report concerns. As part of our supplier vetting, we encourage our business partners to provide training to their staff and suppliers and providers and agree to undertaking our ethics training.

No violations against the prohibition of modern slavery and human trafficking were identified in 2019-2020. Following a review of the effectiveness of the steps we have taken so far we intend to implement the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

• Vetting procedures. The number/percentage of suppliers and sub-contractors that have been vetted for ethical labour practices.
• Supplier screening. The number and type of issues identified on screening suppliers and sub- contractors.
• Tier of supplier. Which tier of supplier has been vetted in a particular year.
• Subcontractor inspections. The number of inspections of sub-contractors.
• Whistleblowing. The number of reported breaches in the past year.
• Training. The number/percentage of staff trained.
• Remedial action. The instances of remedial action being needed.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st March 2020. It was approved by the board on 30th April 2020.

Carl Garrud
Managing Director
On behalf of Rhomberg Sersa Rail Group UK
Date: 30th April 2020