Modern Slavery and Human Trafficking Statement 2025

Waste Collection Islington is committed to conducting all aspects of our operations in an ethical, transparent and socially responsible manner. This Modern Slavery and Human Trafficking Statement sets out the steps we take to prevent modern slavery, human trafficking, forced labour and exploitation within our business operations and supply chains.

Modern slavery is a crime and a serious violation of fundamental human rights. It can take many forms, including slavery, servitude, forced or compulsory labour and human trafficking. We recognise our responsibility to identify, prevent and address any potential risks of modern slavery wherever we operate and from whomever we procure goods or services.

Zero-Tolerance Policy

We operate a strict zero-tolerance policy to modern slavery and human trafficking. Any form of exploitation is completely incompatible with our values, our responsibilities to the community and our obligations under law. This applies to our own employees, agency staff, contractors, suppliers, and any other third parties working on our behalf.

All managers are responsible for ensuring that their teams understand this policy and comply with it in their day-to-day activities. Breaches of this policy by employees may result in disciplinary action, up to and including dismissal. We also reserve the right to terminate our relationship with any supplier, contractor or partner that is found to be involved in modern slavery or that fails to take adequate steps to prevent it.

Our Supply Chain and Supplier Standards

Our supply chain includes providers of vehicles, equipment, uniforms, facilities management, recruitment services and a range of professional and operational support services. We expect all suppliers to uphold high standards of human rights and labour practices equivalent to our own.

As part of our procurement and contract management processes, we require suppliers to confirm compliance with all applicable employment, labour and human rights legislation. We emphasise the prohibition of forced labour, child labour, human trafficking, debt bondage and any form of exploitation. Where appropriate, our contracts incorporate clauses allowing us to review, audit and, where necessary, terminate relationships when standards are not met.

Supplier Audits and Due Diligence

We conduct proportionate risk-based due diligence on existing and new suppliers. This may include pre-qualification questionnaires, self-assessment forms, review of labour practices and, where warranted by risk, on-site or remote audits.

Supplier audits focus on working conditions, recruitment practices, payment of wages, use of labour agencies and subcontractors, and access to grievance mechanisms. Where concerns are identified, we work with the supplier on corrective action plans and monitor progress. Failure to remedy serious issues within agreed timeframes may result in suspension or termination of the business relationship.

Reporting Concerns and Whistleblowing Channels

We encourage anyone connected to our operations, including employees, agency workers, contractors and suppliers, to raise concerns about modern slavery or unethical labour practices. Reports can be made to line managers, senior management or our designated compliance contact. Individuals may also report concerns through our internal whistleblowing channel, which allows confidential reporting without fear of retaliation.

All concerns raised are treated seriously and investigated promptly. Where appropriate, we will involve external authorities and cooperate fully with any official investigations. We will not tolerate any form of victimisation of individuals who raise concerns in good faith.

Training and Awareness

We are committed to increasing awareness of modern slavery risks across our organisation. Relevant staff, including those in procurement, contract management and site supervision roles, receive training on recognising indicators of exploitation and the correct procedures for reporting concerns.

Through internal communications and guidance, we reinforce our expectations of ethical conduct and remind employees and suppliers of our zero-tolerance stance and reporting channels.

Monitoring, Governance and Annual Review

Responsibility for overseeing our approach to modern slavery rests with senior management, who review our policies, risk assessments and mitigation measures. We monitor key indicators such as audit findings, supplier non-compliance, reports raised and remedial actions taken.

This Statement is reviewed at least annually to ensure it remains accurate, effective and aligned with legal and best practice developments. As part of this review, we assess the effectiveness of our due diligence, supplier audits, training and reporting mechanisms and identify opportunities for continuous improvement.

Waste Collection Islington remains firmly committed to preventing modern slavery in all its forms and to working collaboratively with employees, suppliers and partners to uphold human rights and dignity throughout our operations and supply chains.