Two takes a socially responsible approach to all aspects of its operations, the impact that these may have on the environment and its role as a leading business in the communities in which it operates. At Two we are committed to acting responsibly and as benevolently as possible with regard to the environment and the people we come into contact with. The main policy areas are:
We are committed to improving our practices to combat slavery and human trafficking and we welcome the introduction of the Modern Slavery Act 2015. This statement will set out the steps that we have taken and will be taking throughout our business and supply chains in order to reduce the risk of slavery and trafficking activities being present within our business operations.
We are a leading provider of office fit-out and refurbishment services operating in the construction sector in the United Kingdom. We directly employ a significant number of people at our London offices and at sites around the UK and occasionally abroad. Two is a substantial business whose annual turnover means that – through our supply chain – several thousand people work on our projects in any single year.
We provide tenants and office occupiers with relocation and refurbishment services including strategic property advice, space planning and interior design, 3D modelling, technology integration, construction and project management and post contact and warranty support management.
To ensure that modern slavery is not occurring in our business we make sure all employees are paid above the Living Wage (www.livingwage.org.uk) and we comply with our obligations under minimum age laws and the Working Time Regulations 1998. We do not allow cash payments, and all payments are by bank transfer only. In addition, all employees are vetted for their right to work in this country.
OUR SUPPLY CHAINS
Our supply chains include suppliers of goods, supplies and materials, and the use of sub-contractors (who also provide temporary labour) for all stages of the refurbishment and fit-out process.
As part of our initiative to identify and mitigate risk in our supply chains we will require all subcontractors to declare that they are aware of and comply with current legislation in relation to Modern Slavery on our vetting form. We will also monitor and update sub-contractor cards with relevant information for modern slavery monitoring annually.
We will ensure that all contracts with new sub-contractors have a requirement to comply with the Modern Slavery Act 2015, including a requirement to check their own supply chains and employees, with appropriate provisions for failure to comply.
POLICIES, COMPLIANCE & TRAINING
Our Modern Slavery Policy reflects 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 are not taking place anywhere in our business and supply chains.
Our HR personnel are responsible for ensuring compliance with this Statement and our Modern Slavery Policy, and for updating and improving our procedures in forthcoming years.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to our staff to ensure staff can recognise and report on risks of modern slavery.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We will monitor and update the steps in this statement on an annual basis in line with our accounting period. 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 31 December 2022.
For and on behalf of Two Ltd