Code of Practice for Ethical Employment

Introduction from the Executive Chairman

A review of our Code of Practice for Ethical Employment has been undertaken and we are committed to upholding our practices to combat slavery and human trafficking.

We have a zero-tolerance approach to modern slavery across our organisation, as well as in our supply chains. We are committed to ensuring that we are not connected to modern slavery in any way. We aim to ensure that our business operates in an open and transparent way and our approach to tackling modern slavery throughout our supply chains is consistent with our obligations under the Modern Slavery Act 2015.

Wakemans has a firm set of organisational values and policies that encompass everything we do, we encourage open door engagement whereby we encourage the views and input from members of staff at all levels. We are justifiably proud of this bottom-up approach, an approach that has ensured our values reflect both our business and our staff. We positively promote these values in our activities and places of work.

  • Clients We treat clients the way we would want to be treated.
  • People We care for our people through a challenging and supportive working environment.
  • Excellence We strive for excellence.
  • Sustainability We care about the effect we have on the environment.

Organisational structure and supply chains

Wakemans is a leading privately owned Construction Cost and Property Consultancy, we are dedicated to advising Clients in respect of the management and cost control of their construction and development projects. We currently operate throughout the UK and within Europe.

As a professional services consultancy our supply chain is relatively limited.

Further information about our structure, services, and locations can be found at

Anti-slavery and human trafficking policy

Policy Statement

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, agents, contractors and suppliers.

Wakemans Limited strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.


We are a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Staff must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
  • Consistent with our risk based approach we may require:
    • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
  • As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
  • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships

Whistleblowing arrangements

We encourage the reporting of any wrongdoing through internal and external whistleblowing procedures. These procedures also contain arrangements to ensure the protection of whistle-blowers. Work to promote awareness of these procedures is planned.

Risk assessment

Modern slavery within our business is considered low risk but we have identified benefits in raising staff awareness of the issues to ensure any concerns within the regions in which we operate or on the projects on which we work, are raised appropriately.

Measuring effectiveness

Our management team will carry out a review exercise annually to gauge the effectiveness of our arrangements.

Staff awareness

To ensure a high level of understanding Wakemans Code for Ethical Employment in our organisation and with our supply chains, we will:

  • Publish the policy via our web site,
  • Issue the policy to new employees on joining our company,
  • Issue the policy when new supplier is engaged.
  • Issue any amendments to the policy via email and company intranet
  • We seek to identify additional training options as and when appropriate.

Further steps

The Wakemans board will annually review the effectiveness of these measures and policy, should we identify areas of improvement we will actively seek to address these over the coming year. Updates will be provided in future statements:
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by Wakemans Executive Chairman.


John D. Woodhall
Executive Chairman
January 2019