What is ‘Modern Slavery’

Modern slavery is an unacceptable, abhorrent, and often hidden crime in which victims are exploited for another’s gain, including through forced labour and domestic servitude. Globally, an estimated 40 million people are trapped in slavery. UK Government statistics show that in 2024, 19,125 potential victims of modern slavery were referred to the Home Office – a 12.9% increase compared to 2022 and the highest annual figure since the National Referral Mechanism (NRM) was established in 2009.

In 2015, the UK Government introduced Section 54 of the Modern Slavery Act to address modern slavery in businesses. This legislation requires companies with an annual turnover above £36 million to produce a Modern Slavery Statement outlining the steps they have taken to prevent modern slavery in their business and supply chains.

Our aim

We are committed to operating ethically and with integrity, and to preventing acts of modern slavery and human trafficking within our operations and across our value chain, both in the UK and overseas.

This includes:

  • Providing colleagues with clear policies and procedures to identify and tackle modern slavery risks.
  • Incorporating modern slavery indicators into our Safe Site Inspections, with central communication and awareness campaigns across client sites.
  • Raising awareness through e-learning modules.
  • Encouraging and enabling safe and confidential reporting of exploitation, particularly among migrant worker communities.
  • Fostering long-term relationships with suppliers who share our commitment to responsible and ethical labour practices.
Policy Integration

This policy works in conjunction with our ESG Policy and Human Rights Policy Statement to ensure a consistent, embedded approach to ethical operations, colleague welfare, and value chain accountability.

Governance and Oversight

Oversight of our modern slavery strategy sits with the Group Risk Committee, ensuring integration with broader ESG governance structures. The committee reviews risks, actions, and stakeholder engagement related to modern slavery and ensures continual improvement across the business.

Policies

We maintain a suite of policies that support compliance with the Modern Slavery Act and reinforce our ethical standards. These include:

  • Anti-Bribery & Corruption
  • Equal Opportunities
  • Ethical Trading
  • Recruitment & Eligibility to Work
  • Vetting & Screening
  • Whistleblowing
  • Working Time Regulations

Our Supplier Charter explicitly requires that suppliers:

  • Prohibit all forms of forced, bonded, or involuntary labour.
  • Ensure workers are treated humanely and with dignity.
  • Maintain legal and ethical recruitment practices.
  • Provide safe working conditions and fair remuneration.

These expectations are communicated clearly and we expect our suppliers and contractors to uphold the same high standards.

Colleague Engagement and Awareness

Colleagues receive training on modern slavery risks and how to identify and report concerns. This is delivered through our mandatory e-learning module available on the company’s training portal. Awareness is reinforced through posters and communication at client sites.

Whistleblowing and Reporting Mechanisms

We encourage individuals to report any concerns related to potential modern slavery or human trafficking through our confidential Whistleblowing Policy. All disclosures are treated seriously and handled confidentially and sensitively.

External Engagement

We utilise the resources and training provided by Stronger Together, including toolkits, workshops, and online modules. These tools help us to continually strengthen our strategy to deter, detect, and deal with exploitation across our operations and value chain.

Our Commitment

To demonstrate accountability and transparency, we commit to:

  • Completing 100% of planned Safe Site Inspections annually, with each inspection including modern slavery checks.
  • Maintaining a 0% incident rate of identified modern slavery cases across operations and supply chains.
  • Ensure a minimum of 90% of colleagues in identified high-risk roles (Payroll, Recruitment, and Operations Management) complete modern slavery awareness training by the end of the next reporting year.
Summary

We are proud to operate a zero-tolerance approach to modern slavery. This statement outlines the proactive systems, collaborative partnerships, and governance structures we have implemented to support our ESG and Human Rights commitments. Through continuous improvement, supplier engagement, and colleague education, we remain steadfast in our mission to eliminate modern slavery and ensure dignity and respect across our business and value chain.

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and the Human Rights Act (1998) for the financial year ending 2024.