At Jacobs, we do things right. We always act with integrity – taking responsibility for our work, caring for our people and staying focused on safety and sustainability. We make investments in our clients, people and communities, so we can grow together. Guided by our values, we have taken a variety of actions to verify the absence of modern slavery in our supply chain, summarized below.
Risks of Modern Slavery in our Operations and Supply Chains
We are committed to identifying possible modern slavery risks in our operations and supply chains. We periodically conduct global supply chain mapping and human rights risk assessments, sometimes with the support of third-party consultants. As a result, we update and improve our understanding of our highest risk areas for human rights and modern slavery exposure.
We have considered four key factors that elevate the risk of modern slavery in our operations and supply chains:
- Sector and industry risks: as an organization that engages in construction-related activities, we understand that we are in an identified high-risk sector or industry.
- product and services risks: we also understand that some products used in our supply chains are identified high risk products.
- Geographic risks: some of the countries that we operate in have higher risks of modern slavery due to poor governance or socio-economic factors.
- Entity risks: the majority of our direct suppliers are leading suppliers and we are not aware of any noncompliance with human rights or labor standards.
We are committed to continuously improving our approach in identifying modern slavery risks in our supply chains and operations.
Our actions to assess and address modern slavery risks
In 2020 we launched our global Human Rights Policy, which details our commitment to respecting the human rights and dignity of individuals within our operations, supply chain and communities where we do business. Additionally, we continue to uphold Jacobs’ global Supplier Code of Conduct, which prohibits the use of any form of child or forced labor, slavery, or human trafficking. Our Supplier Code of Conduct applies to all of our suppliers, vendors and subcontractors.
Supporting our Human Rights Policy, we introduced an updated human rights prequalification questionnaire into our supplier screening process. We conduct ongoing due diligence of suppliers based on international indices, media searches and other indicators of supplier risk. We are also undertaking a wide-ranging review, rationalization and improvement of our procurement systems to further strengthen internal controls, consistency and data visibility.
Contracting and Certification
Our standard contracts stipulate that suppliers will comply with all applicable laws, rules and regulations including those related to human trafficking and worker welfare. We also require that suppliers who receive a purchase order or subcontract from Jacobs certify compliance with our Supplier Code of Conduct, including its human rights provisions.
We engaged a third-party consultant in Australia to review our template subcontract and draft specific modern slavery provisions.
As part of our supplier management process, suppliers may be required to demonstrate conformance and assurance that, where applicable, they have flowed down our requirements to their suppliers. Whenever possible, we operate in a spirit of continuous improvement, working with suppliers to implement change within specified timeframes. Looking ahead, we have identified and are training additional internal resources to provide support in high-risk areas.
Our standard training for supply management professionals includes a section on our Supplier Code of Conduct, and we are building capacity across key staff to enhance supplier engagement regarding human rights. Additional training and engagement activities will be developed as appropriate as we continue to advance our human rights and modern slavery program.
Jacobs recognizes the importance of stakeholder engagement to create a more connected, sustainable world. We are proud to be a signatory to the United Nations Global Compact and a founding member of Building Responsibly, an industry group consisting of leading engineering and construction related companies collaborating to promote the rights and welfare of workers globally. Additionally, we have engaged with representatives from the U.S. and U.K. governments to provide collaboration and thought leadership regarding human rights and the prevention of modern slavery in corporate supply chains.
Our approach to assessing effectiveness
Key Performance Indicators
Our Supply Management organization has responsibility for monitoring supplier qualification and certification with our Supplier Code of Conduct. Our global, cross-functional working group is evaluating and updating our human rights strategy to foster good practice and enhanced controls across the business. Part of this effort includes establishing practical and meaningful key performance indicators to measure progress against our goals.
We encourage our employees, suppliers and stakeholders to speak up, without retribution, about any concerns regarding human rights and modern slavery in our operations or supply chain. As detailed in our Supplier Code of Conduct and on our website, anyone can submit a report anonymously through the Jacobs Integrity Hotline at integrity.jacobs.com or by calling +1.844.543.8351. We are committed to investigating reports in an appropriately robust and timely manner.
Our consultation process
We communicated our commitments and actions in combatting modern slavery to the relevant entities in our operations. We have ensured that all relevant areas of Jacobs are aware of what actions need to be taken to identify, assess and address modern slavery risks in our operations and supply chains.
This statement has been made in accordance with the reporting requirements of Clause 54, Part 6 of the UK Modern Slavery Act 2015 and section 16 of the Australian Modern Slavery Act 2018 for the financial year ended 30 September 2020 and applies to the UK business of Jacobs which includes, but is not limited to, the following subsidiaries: Jacobs U.K. Limited, Jacobs Field Services Limited, CH2M Hill United Kingdom, CH2M Hill International Nuclear Services Limited, Halcrow Group Limited, Halcrow International Partnership, Jacobs Clean Energy Limited and Energy, Safety & Risk Consultants (UK) Limited (collectively "Jacobs UK") and Jacobs Group Investments Australia Pty Ltd and Jacobs Australia Pty Ltd.
This statement was approved by Jacobs Group Investments Australia Pty Ltd on 24 March 2021.
This statement was approved by Jacobs Australia Pty Ltd on 15 March 2021.
This statement was approved by Jacobs UK boards on 16 March 2021.
EVP, Chief Legal and Administrative Officer