Modern Slavery Act Transparency Statement

Modern slavery and human trafficking

At Nova Structures Limited (‘Nova’) we aim to have transparent business operations and performance. We follow a high set of ethics and values and these guide our governance procedures and management decisions. We are committed to expanding our operations globally in a sustainable manner for the benefit of our customers, employees, and the wider community. We take our corporate responsibility very seriously and this forms the foundation of our strategy and business decisions.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and explains the measures Nova has taken to prevent slavery and human trafficking in its business and supply chain during the last financial year ending 31 March 2021.

Nova’s Main Business

Nova Structures is a company that delivers precision-engineered homes. We work collaboratively with our partners to create homes to meet local requirements. More details of our business are available on our website.

Our supply chain:  We have a small, specialist, supply chain, with the majority of approved key suppliers being based in Europe. Relationships are strengthened through regular and ongoing supplier approval visits, so that any who are operating or sourcing from high-risk countries, where modern forms of slavery are prevalent, can be quickly identified and audited.

Our Policies in relation to Slavery and Human Trafficking

Nova has a recruitment process in place which involves ensuring that pay and working conditions are appropriately managed.

Nova has maintained policies and procedures to ensure that all business is conducted in a transparent, ethical, and responsible manner, thus remaining compliant with the Modern Slavery Act 2015. Nova’s modern slavery and Human Trafficking Policy sets out Nova’s zero tolerance stance and explains Nova’s procedures to ensure modern slavery and human trafficking is not taking place in its business and supply chain, including how suspected breaches can be reported.

Terms and Conditions of Purchase

Nova’s terms and conditions of purchase imposes a requirement to comply with our Modern Slavery and Human Trafficking Policy.

Other existing policies such as the ones below are designed to ensure compliance to high ethical standards of behaviour throughout the organisation, fair treatment of all colleagues, and an open culture where any concerns can be raised with Management:

• Anti- Bribery and Corruption Policy;
• Whistleblowing Policy; and
• Grievance Policy.

As part of the Whistleblowing Policy, Nova has introduced a confidential online reporting system to ensure an easy means of reporting any policy violations.

Our Due Diligence Processes

Following the publication of the Modern Slavery Act, Nova has introduced further due diligence on the supply chain as part of the approval process leading to preferred supplier status.  We continue to consider where our business and supply chain is most at risk.

We request that key suppliers provide their policies on anti-slavery and human trafficking, as well as any other policies that show they operate with clear ethical responsibility towards their workforce, and comply with legislative requirements, for example on pay, equal treatment and working conditions.

Nova does not support or knowingly deal with any business involved in slavery or human trafficking. We will not work with any company in breach of the Nova Modern Slavery and Human Trafficking policy or identified as having slavery and human trafficking in its business or supply chains.

Looking Ahead

Nova will implement mandatory training on the requirements of the Modern Slavery Act, and we will provide further training as required for any other managers involved in the supply chain function to ensure they can evaluate the risks and recognise signs of modern slavery and human trafficking.

Following a review of the effectiveness of the steps we have taken this year to ensure there is no slavery or human trafficking in our supply chains we intend to continue to critically evaluate the policies we have put in place to prevent slavery and human trafficking taking place in its business and supply chain.

We will report and act on any reports or notifications from staff or external authorities, including prosecutions or criminal charges, and thus ensure no forms of compulsory labour and human trafficking take place in our business and supply chain.  Throughout the next year, we shall continue to engage with our preferred suppliers to ensure compliance with our Supplier Code of Conduct.

Terry Wood
Managing Director
Nova Structures Limited, May 2021