Modern Slavery and Human Trafficking Statement

Waste Collection Crystal Palace is committed to conducting all aspects of our operations ethically, responsibly, and in full compliance with applicable laws. We recognise that modern slavery, human trafficking, forced labour, and exploitation are severe violations of fundamental human rights. This statement sets out the steps we are taking to prevent, identify, and address the risks of modern slavery within our operations and supply chains.

Our Business and Supply Chain

We provide waste collection, recycling, and related environmental services to residential, commercial, and public sector clients. Our activities rely on a network of suppliers and service partners, including vehicle and equipment providers, maintenance contractors, personal protective equipment suppliers, facilities management providers, and labour agencies. We understand that risks of modern slavery may arise at different tiers of our supply chain and we are committed to continuous improvement in assessing and mitigating those risks.

Zero-Tolerance Policy on Modern Slavery

We operate a clear zero-tolerance policy towards modern slavery and human trafficking in all their forms. This applies to our own operations, our employees, agency workers, contractors, and every organisation with which we do business. We will not knowingly engage with any supplier or partner that is involved in, or fails to take adequate steps to prevent, modern slavery. Where credible concerns arise, we will take prompt action, which may include investigation, remedial measures, suspension of trading, or termination of contracts.

Governance, Roles and Responsibilities

Responsibility for our modern slavery approach rests with the senior management team, which provides oversight, sets expectations, and reviews progress annually. Operational managers are responsible for implementing this statement in day-to-day activities, including supplier selection, contract management, and workforce engagement. All employees share responsibility for upholding our standards, reporting concerns, and cooperating with any investigations into suspected exploitation.

Supplier Standards and Audits

We expect all suppliers and service partners to operate to high ethical, social, and labour standards. Our procurement processes include checks aimed at identifying risks of modern slavery, such as reviewing labour practices, use of subcontractors, and geographic and sector-based risk factors. We reserve the right to audit suppliers, either directly or through competent third parties, to verify compliance with our requirements. These audits may include document reviews, site visits, and confidential interviews with workers where appropriate. Non-compliance is addressed through corrective action plans, close monitoring, or disengagement from the supplier.

Due Diligence and Risk Assessment

We conduct ongoing due diligence to understand and manage the risks of modern slavery in our business and supply chains. This includes assessing categories of spend and regions that may present higher risk, scrutinising labour providers and subcontractors, and integrating modern slavery considerations into contract award and renewal decisions. We keep records of identified risks and actions taken to address them, with a focus on prevention, remediation, and continuous improvement.

Training and Awareness

We provide relevant training and guidance to employees, particularly those involved in procurement, contract management, and frontline operations. Training covers recognising signs of forced labour and exploitation, understanding our zero-tolerance stance, and knowing how to escalate concerns. We aim to foster a culture in which workers feel confident to speak up if they suspect unethical or unlawful practices in our business or supply chain.

Reporting Channels and Whistleblowing

We encourage anyone connected with Waste Collection Crystal Palace, including employees, contractors, agency workers, and suppliers, to report concerns about modern slavery or unethical labour practices without fear of retaliation. Concerns can be raised through line managers, senior management, or our dedicated whistleblowing channel. Reports may be made confidentially and will be treated seriously, investigated promptly, and handled with sensitivity. We will not tolerate any form of victimisation against individuals who raise concerns in good faith.

Monitoring, Review and Continuous Improvement

We are committed to regularly reviewing the effectiveness of our actions to combat modern slavery. This Modern Slavery Statement is reviewed annually by senior management to ensure that it remains accurate, relevant, and reflective of our current practices and evolving legal requirements. As part of the annual review, we consider audit findings, reported concerns, supplier performance, and feedback from workers and partners. We use this information to strengthen our policies, training, and due diligence processes year on year.

Approval and Publication

This statement has been approved by the senior management of Waste Collection Crystal Palace and represents our ongoing commitment to preventing modern slavery and human trafficking in our operations and supply chains. It will be updated and published annually to reflect our progress and any changes in our approach.