United Kingdom Modern Slavery Act Statement 2017

Protecting the health, safety, and welfare of workers is of the utmost priority to CH2M, and is supported at the highest levels of our company. Our industry-leading Worker Welfare Policy and collaborative spirit place us at the forefront of our industry in addressing the risks of slavery and human trafficking, both within our operations and across our sector.

Construction workers at a project site

CH2M UK Entities:

  • CH2M HILL Europe Ltd
  • CH2M HILL International Nuclear Services Ltd
  • CH2M HILL United Kingdom
  • Halcrow Consulting Engineers & Architects Ltd
  • Halcrow Consulting Ltd
  • Halcrow Group Ltd
  • Halcrow Holdings Ltd
  • Halcrow International Ltd
  • Halcrow International Partnership
  • Halcrow Management Sciences Ltd

For a more detailed overview of CH2M’s activities related to human rights and worker welfare, see CH2M’s 2016 Sustainability and Corporate Citizenship Report – both the Human Rights section and the worker welfare cover story.

CH2M leads the professional services industry delivering sustainable solutions benefiting societal, environmental, and economic outcomes with the development of infrastructure and industry. In this way, CH2Mers make a positive difference providing consulting, design, engineering and management services for clients in water, environment and nuclear, transportation, and energy and industrial markets, from iconic infrastructure to global programs like the Olympic Games. Ranked among the World’s Most Ethical Companies and top firms in environmental consulting and program management, CH2M in 2016 became the first professional services firm honored with the World Environment Center Gold Medal Award for efforts advancing sustainable development.

Since we began operations over 70 years ago, CH2M has placed a very high importance on the human rights of our employees and others working with CH2M. At the heart of our commitment to ethical behavior is The Little Yellow Book, a simple but powerful set of guiding principles written for CH2M employees by one of our founders more than 40 years ago. We apply these ideas through a range of programs and policies governing how we select partners and suppliers, promote the welfare of workers in our supply chain, and more.

We support global efforts to tackle modern slavery, and CH2M is fully committed to comply with the UK Modern Slavery Act and undertake all necessary steps to prevent slavery and human trafficking within our operations and within our supply chain. CH2M firmly believes it is our obligation to support and protect the health, safety, welfare, and security of each worker we engage on our projects. Ethical recruitment and employment practices, safe work practices, as well as safe and healthy living and working conditions are crucial elements of our way of delivering work.

CH2M has established and maintains high worker welfare standards for our employees and individuals working on projects on our behalf. Specifically, we have developed a Worker Welfare Policy, which we share with our clients, supply chain, and peers. Our Worker Welfare Policy outlines the fundamental ethical principles related to working for and on behalf of CH2M, and provides guidance on recruitment practices, workers’ management, accommodation, and safety. We strive to influence other firms in our industry to adhere to the practices outlined in this Policy along with local legislative requirements and regulations.

We commit to continuously improving our services to clients in this area by engaging with relevant stakeholders and drawing from international best practices. Our Ethics and Business Conduct policies, in particular our Worker Welfare Policy, are integral to all our supplier and sub-contract contracts, setting out our strong commitment to anti-corruption, health and safety, environmental protection, legal compliance, and ethical conduct.

CH2M globally, and within our UK operations, has taken these steps to implement a robust approach to combatting slavery and human trafficking:

  • We partnered with Verité, a leading human rights organization, to develop our Worker Welfare Policy, which outlines all requirements relating to anti-slavery and human trafficking. Supporting our Policy is a series of guidance notes that provide the internal procedures and management systems to operationalize our worker welfare requirements. This includes effective grievance and whistle blowing mechanisms which cover concerns about slavery or human trafficking within any part of our business or supply chain.
  • As part of CH2M’s global worker welfare strategy, we have co-hosted a series of a multi-stakeholder roundtables designed to bring major engineering and construction firms together on implementation of the Modern Slavery Act and improving worker welfare. Under CH2M’s leadership, these roundtables have resulted in the formation of a new industry organization focused on the rights and welfare of workers. We have also participated in a number of industry and human rights events where we have been featured as guest speakers.
  • Our program around worker welfare and human rights is sponsored by a high-level company executive, our General Counsel, and this statement has been approved by our UK Board of Directors.
  • CH2M has undertaken a review of its procurement process and implemented measures to identify and prevent modern slavery in the prequalification process for suppliers, consultants, sub-contractors, and partners. All our suppliers are subject to appropriate and robust due diligence, and we have included contractual language related to worker welfare in relevant contracts.
  • CH2M in the UK has convened a multifunctional working group including HR, HSEQ, Government Affairs, Ethics, Legal, and Procurement to implement the requirements of the Modern Slavery Act. The working group has reviewed the implications of the Act and has amended our management systems to be compliant.
  • Upon joining CH2M, new employees receive a copy of our Employee Ethics & Business Conduct Principles, which clearly describes our expectations about fair labor practices, trafficking in persons, and other important principles related to how CH2M does business. Additional education on human rights is provided for employees who are likely to confront these issues in specialized ethics and compliance trainings.
  • In support of our human rights and labor practices expectations, we distribute our Supply Chain Ethics & Business Conduct Principles to our major suppliers.
  • All our employees have to undertake a mandatory annual Ethics and Business Conduct training; we have incorporated worker welfare and Modern Slavery Act awareness into this training. Completion of this training is fully tracked for all employees.
  • As part of our ongoing compliance effort, CH2M in the UK has undertaken a Modern Slavery Act 2015 risk assessment of our operation, and has identified possible activities with elevated risk. Such activities and associated suppliers will be subject to an internal compliance audit, as set forth in our Worker Welfare Policy. From these activities we will determine performance indicators and future steps to assess and manage ongoing risk.

Endorsed by:
Tom McCoy,
CH2M General Counsel
17 February 2017