Modern Slavery, Ethical Working & SHEQ Policy

This policy sets out Bia Electric Ltd’s approach to modern slavery, ethical working and Safety, Health, Environment and Quality (SHEQ).

It is intended to be practical rather than ceremonial. Bia Electric Ltd does not regard possession of a policy, certificate or accreditation as evidence by itself that people are safe or being treated ethically. The purpose of governance is to influence real decisions: how work is planned, how people are paid, how risks are communicated, how suppliers are selected and, critically, whether a person genuinely feels able to stop when something is wrong.

We therefore seek to go beyond passive compliance. Applicable legislation, standards and recognised industry practice establish important minimum expectations, but they do not remove the need for professional judgement, critical thought and continual improvement.

Bia Electric Ltd’s approach is based on the following principles:

This policy applies, as appropriate, to:

The policy applies to Bia Electric Ltd’s electrical, renewable-energy, technical, consultancy, training and associated activities.

Bia Electric Ltd has zero tolerance for modern slavery, forced labour, human trafficking, servitude, compulsory labour or exploitation.

We recognise that exploitation does not always present itself in an obvious form. Risk can arise through subcontracting, recruitment practices, withholding of wages or documents, excessive dependency upon an employer or intermediary, coercive working arrangements, unsafe accommodation, unreasonable deductions, debt, threats, or circumstances in which a worker does not realistically feel free to refuse or leave work.

We will not knowingly participate in, benefit from or continue a business relationship involving modern slavery or serious labour exploitation.

Bia Electric Ltd operates in electrical and renewable-energy supply chains that can extend through wholesalers, manufacturers, logistics providers and international sources of raw materials and components.

We do not claim that a small business can independently audit every tier of a global supply chain. We do, however, accept responsibility for making proportionate decisions about the organisations with which we choose to do business.

Where appropriate to the scale and nature of a purchase or relationship, we may consider:

A concern does not automatically establish wrongdoing. It should, however, prompt proportionate enquiry rather than being ignored for commercial convenience.

Where a credible serious concern cannot be satisfactorily resolved, Bia Electric Ltd may suspend purchasing, seek an alternative supplier, escalate the matter or terminate the relationship where proportionate and lawful.

Bia Electric Ltd considers worker autonomy to be both an ethical issue and a safety control.

People undertaking work for us should have genuine freedom to raise concerns, refuse an unsafe instruction and stop work where they reasonably believe continuing would expose themselves or others to unacceptable risk.

Where reasonably practicable, our commercial and payment arrangements should support that freedom.

Payment should therefore not usually be made wholly contingent upon successful completion of a task where that arrangement could create an incentive to continue after conditions have become unsafe, materially different from those anticipated, or outside the person’s competence or authority.

Where somebody stops work in good faith because of a genuine safety concern, the fact that the intended task was not completed should not by itself be treated as misconduct or a reason to withhold payment properly due for work undertaken.

This principle is not intended to remove normal commercial accountability for performance. It is intended to ensure that nobody has to choose between an immediate financial penalty and making a reasonable safety decision.

Any person undertaking work for Bia Electric Ltd is encouraged to stop and reassess where they reasonably believe:

Stopping is not necessarily the end of the job. It is a deliberate decision point: stop, communicate, reassess and agree what happens next.

Nobody should be criticised merely for making a good-faith stop-work decision. Deliberate misuse of this principle can still be managed through ordinary performance or contractual processes.

Bia Electric Ltd rejects the idea that safety begins at the site gate.

Risk assessment and work planning should consider the reasonably foreseeable risks associated with the complete work activity. Depending upon the job, this can include:

Where travel is undertaken as part of the work activity, relevant travel risks should be considered as part of planning and risk assessment rather than being automatically treated as somebody else’s problem.

Human decision-making is affected by sunk cost. Once somebody has driven several hours, spent money, committed equipment, promised a completion date or worked most of a day, there is a natural pressure to continue because of what has already been invested.

Bia Electric Ltd explicitly recognises this as a potential safety risk.

Statements such as “we have come this far”, “the customer expects it today”, “we only have one more thing to do” or “we cannot afford another visit” do not constitute safety controls.

When circumstances change, the correct decision should be based on the risk and information available now, not on the amount already spent getting to that point.

Managers, engineers and subcontractors should therefore distinguish between:

Both may be relevant to the business decision, but cost already incurred must not be allowed to disguise or normalise an unacceptable safety risk.

Good safety management includes good expectation management.

Engineers and subcontractors are expected to communicate emerging problems as soon as reasonably practicable rather than allowing a preventable surprise to develop at the end of a job.

Where conditions change, communication should explain, as appropriate:

Managers and directors have a corresponding responsibility to manage customer and stakeholder expectations. An engineer should not be expected to absorb unsafe pressure simply because an unrealistic expectation has previously been communicated to a customer.

Early, clear and honest communication is therefore treated as a risk control in its own right.

A written risk assessment is a starting point, not a prediction of everything that will happen.

People undertaking work are expected to continue assessing conditions throughout the task. If the assumptions on which the original assessment was based are no longer true, the assessment and method of work should be reconsidered.

Dynamic assessment does not mean improvising around an unsafe condition. It means noticing change, stopping where necessary, thinking again and obtaining additional support where required.

People should work within the limits of their competence, training, experience and authority.

Bia Electric Ltd does not regard asking for assistance as evidence of incompetence. Recognising the boundary of one’s knowledge is itself an important professional skill.

Where uncertainty could materially affect safety, quality or compliance, the preferred response is to verify the information, consult an appropriate competent person, manufacturer, standard or authoritative source, or stop until the issue can be resolved.

Guessing because a customer is waiting is not an acceptable substitute for competence.

Incidents and near misses should be reported and considered proportionately.

Our first questions should normally be:

This is not a no-accountability policy. Deliberate disregard of safety, dishonesty, reckless conduct or repeated refusal to follow reasonable controls may require corrective action.

However, automatically blaming the last person who touched the equipment is rarely a satisfactory investigation. We seek to understand the system as well as the individual action.

Employees, subcontractors and other people working with Bia Electric Ltd are encouraged to raise concerns about:

People should be able to say “I don’t know”, “I made a mistake”, “I think this is unsafe” or “I think we need to stop” without unnecessary embarrassment or hostility.

Good-faith challenge is welcomed even when the concern ultimately proves unfounded. A culture in which people hide uncertainty is more dangerous than one in which reasonable questions are occasionally unnecessary.

Concerns may be raised directly with a Director of Bia Electric Ltd — use the contact form and mark your message for the attention of the Directors. Serious concerns will be considered promptly and proportionately.

Fitness for work includes more than the absence of an obvious physical injury.

Fatigue, excessive hours, illness, stress, medication, heat, cold and other factors can affect judgement and physical performance. People are encouraged to raise such concerns where they could materially affect safe work.

Work should be rescheduled, adapted or stopped where a relevant condition makes the planned activity unreasonably unsafe.

Bia Electric Ltd seeks to minimise avoidable environmental harm arising from its activities.

This includes proportionate consideration of waste, materials, unnecessary travel, responsible disposal, reuse and recycling, pollution prevention and the environmental consequences of purchasing decisions.

Our work in renewable energy does not exempt us from examining the environmental impact of how that work is delivered.

Quality is not treated as separate from safety and ethics.

Poor workmanship, incomplete records, inappropriate substitutions, rushed commissioning or concealed defects can create risks long after an engineer has left site.

Work should therefore be completed, tested, recorded and communicated to an appropriate standard. Where something cannot be completed correctly, the preferred response is to identify and communicate the limitation rather than disguise it.

Contractors and suppliers working with Bia Electric Ltd are expected to share the substance of these principles even where their own policies use different terminology.

We do not require every small supplier to possess a particular certification merely to demonstrate competence or ethical behaviour. Equally, possession of certification does not remove the need to consider actual conduct.

Where appropriate, repeated or serious failures relating to safety, quality, employment practices, environmental conduct or honesty may affect future purchasing or engagement decisions.

The level of formal training and communication associated with this policy will be proportionate to the size and activities of the business.

Relevant principles should be communicated to people undertaking work on behalf of Bia Electric Ltd, particularly the authority to stop unsafe work, the expectation to communicate changing risks and the means of raising serious concerns.

Where proportionate to the activity, Bia Electric Ltd may retain evidence including risk assessments, method statements, photographs, test results, commissioning records, training or competence records, supplier information, incident records and communications concerning significant safety or ethical issues.

Records exist to support safe work, accountability, learning and traceability. Documentation should serve the work rather than become an end in itself.

The Directors of Bia Electric Ltd have overall responsibility for this policy.

Everyone undertaking work for the company also has a responsibility, appropriate to their role, to act safely, communicate honestly, protect others who may be affected by their work and raise material concerns.

The company will seek to allocate responsibility to the person or organisation best placed to control a risk rather than automatically transferring it down the contractual chain.

This policy will be reviewed at least annually and sooner where appropriate following:

Review should ask not merely whether the policy was followed, but whether the policy itself remains sensible.

Bia Electric Ltd’s approach to Modern Slavery and SHEQ is deliberately proactive and human-centred.

Rules, procedures, standards and certifications are useful tools, but they are not substitutes for judgement, communication and the freedom to make a safe decision.

We want the person doing the work to be able to stop before an accident rather than explain afterwards why they felt they had no choice but to continue.

We therefore judge the effectiveness of this policy not by its length or the number of certificates on a wall, but by whether it helps people make better decisions when circumstances become difficult.