Modern Slavery Act Transparency Statement 2021

This statement is made in accordance with section 54 of the Modern Slavery Act 2015 on behalf of Arcadis Gen Holdings Limited and its UK subsidiaries.

Our Structure

Arcadis Gen is a global digital services company that develops and implements digital solutions in the construction, infrastructure and environment sectors. We have over 200 members of staff.

We are committed to improving quality of life through maximizing our impact for our people, for clients and society. We put sustainable solutions and digital leadership at the heart of everything we do – through our products and projects, in our communities and in our work for clients, we enhance human experiences and foster personal, societal and business growth.

Our Policies and Standards on Modern Slavery

As a member of the Arcadis Group of companies, Arcadis Gen Holding Ltd (“Arcadis Gen”) carries out its business activities in compliance with the Arcadis General Business Principles ("AGBP") which can be found here. The AGBP are expressed as a set of commitments: commitments towards our clients, shareholders, business partners and employees, the public, and to governments and the laws and culture of the countries in which we operate.

Integrity is one of the core values under which Arcadis Gen operates. The AGBP specifically commits that “Arcadis values its employees as a key asset and respects their human and labor rights so that they may work in a safe, healthy, professional, and supportive environment.”

To help us further assess the risk of modern slavery, we also have internal policies and guidance for working in sanctioned countries and risk-based due diligence processes for engaging with third parties that should also help flag any potential modern slavery issues at an early stage. In addition, we have Dignity at Work and Grievance people policies that help in providing a supportive and safe environment for our employees.

Risk Assessment

Due to the professional services nature of our business’ work, we believe the risk associated with slavery and human trafficking within our business is relatively low.

However, we acknowledge that the key risk areas regarding slavery and human trafficking lies within:

• Our supply chain; and
• Our recruitment processes.

We manage these risk areas through the procedures referred to within this Statement.

Our Supply Chain

Our supply chain generally comprises the following:

• Professional services organizations such as sub-consultants, partners, contingent workers, agencies and suppliers; and
• Business operational support such as suppliers who provide goods and/or services to facilitate the running of the business.

However, regardless of the business relationship, (1) our standard contractual terms with third parties contain appropriate clauses confirming that they carry out their business in accordance with principles consistent with the AGBP and in compliance with the Modern Slavery Act and (2) every supplier must acknowledge and that they have read and understood the AGBP.

Our Recruitment Processes

To manage the risks associated with our recruitment processes, our approach usually includes an interview process which is carried out in person. This process is designed to ensure that prospective employees share our values and behaviors, have the necessary competence but also that they have applied to work with us of their own free will.

In addition, right-to-work checks are carried out on all new Arcadis Gen employees and an individual’s employment with us is conditional upon them having the legal right to work in the UK or Ireland as appropriate.

During the initial stages of the Covid-19 pandemic, Arcadis put in place a temporary restriction on the recruitment of non-critical roles including contingent workers. Once the recruitment restriction was lifted, and in accordance with Home Office guidance, we adapted our Right to Work process to allow for virtual checks.

Due Diligence

We also undertake various steps to prevent modern slavery or human trafficking from occurring within our business and supply chain. For example, we undertake risk-based due diligence on engagements with all third parties such as JVs, Agents etc. Part of that due diligence includes carrying out searches for reputational or integrity related issues.

In addition, all new sub-consultants, contingent workers, agencies and suppliers must be approved through our supplier due diligence process in order to provide services to us.

Reporting

We maintain a telephone and web-based Integrity Line through which integrity issues can be reported anonymously. Contact details are available to all employees on the intranet. All issues reported through the Integrity Line are followed up by the Arcadis Gen Compliance Officer and/or Compliance Committee as appropriate.

Measuring Effectiveness

As the risk of slavery and trafficking occurring in our business is low, we normally monitor our suppliers through our robust onboarding procedures, project auditing, site walks and through the supply chain feedback.

There have been no issues raised internally or externally relating to modern slavery.

Training for Staff

We train all our employees on ethics and integrity. Compliance with our core values and AGBP is a mandatory part of the induction process. A refresher of the AGBP is carried out every two years with the most recent training cycle undertaken in 2020.

Targeted training on the Modern Slavery Act has been provided to those most relevant within the business, for example, our contingent workers team.

Covid-19

We do not believe that the pandemic has increased the overall risk of modern slavery or human trafficking occurring within our business and so our key risk areas have remained the same. Our priorities during this time have been employee health and safety, supply chain management and our recruitment process.

We continue to monitor the impacts of Covid-19 on our business and adapt processes accordingly.

Approved by: Rachel White, Chief Executive Officer, Arcadis Gen