Modern Slavery Statement for Waste Recycling

Zero-tolerance is at the core of our waste recycling modern slavery statement. Our organisation maintains an uncompromising position: we will not accept forced labour, human trafficking or any form of modern slavery in our operations or supply chains. This policy applies across collection services, transfer stations, processing centres, transport partners and subcontracted labour, and is actively communicated to employees, contractors and suppliers at every stage.

We maintain a comprehensive policy framework that sets clear expectations for standards of conduct across the recycling supply chain. All suppliers are required to adhere to our Supplier Code of Conduct and must confirm compliance during onboarding and at contract renewal. We operate a risk-based approach to identify higher-risk materials, services and geographies and apply enhanced due diligence where necessary. Training on modern slavery risks is provided regularly to procurement teams, operational managers and frontline staff to ensure consistent, practical implementation of the policy.

Supplier audits form a critical component of our due diligence. We undertake on-site inspections, remote assessments and documentary reviews to verify employment terms, wage payments, working hours, health and safety and subcontractor arrangements. Our supplier audit programme includes:

• Risk-based audit scheduling prioritising high-risk suppliers, geographies and activities
• Use of independent third-party auditors to provide objective verification
• Clear corrective action plans with time-bound remediation and validation checks
• Escalation processes including contractual sanctions up to termination for persistent non-compliance

Due Diligence, Procurement and Worker Protections

We integrate modern slavery checks into procurement, tendering and contracting processes for recycling and waste management services. Contract clauses require suppliers to permit audits, maintain accurate employment records and ensure the free movement and consent of workers. We also require suppliers to provide evidence of recruitment practices, agency oversight and prohibitions on recruitment fees. Non-compliance with these clauses will trigger remediation steps and may lead to contract suspension or termination. Our commitment covers permanent, temporary and agency workers across all operational sites.

Reporting channels are established to encourage safe, confidential and anonymous reporting of suspected modern slavery or unethical practices. Employees, contractors and external partners can raise concerns through a secure whistleblowing service, direct reporting to line management, and escalation to our ethics and compliance committee. Reports are logged, triaged and investigated promptly with appropriate protections against retaliation; findings inform corrective action and supplier performance assessments.

We maintain a clear investigation, remediation and victim-centred support process. Where an issue is identified we will collaborate with suppliers, local authorities and specialist organisations to remediate harm, support affected individuals and restore safe working conditions. Remediation may include compensation, medical and legal support or facilitated repatriation where appropriate. If remediation is not feasible or reliable, we will terminate supplier relationships and pursue contractual remedies while ensuring victims receive appropriate support.

Monitoring, Collaboration and Continuous Improvement

Monitoring includes ongoing data collection, supplier performance metrics, and review of corrective action effectiveness. We track key performance indicators such as audit completion rates, number of breaches found, time to remediation and training completion rates. Findings are reported to senior leadership and the governance committee to inform policy updates and resourcing decisions. Collaboration with industry groups, NGOs, and peers in the waste recycling sector enhances our ability to detect trends and share best practices.

Enforcement of our zero-tolerance policy is operationalised through supplier onboarding checks, contractual clauses, audit requirements and defined termination rights. We expect partners and subcontractors to cascade the same standards to their own supply tiers; failing to do so triggers our escalation framework. We also promote worker engagement and anonymous grievance mechanisms at processing sites to ensure concerns are surfaced early and addressed effectively.

Annual review: this Modern Slavery Statement for recycling operations is reviewed at least annually by our governance committee to assess effectiveness, update risk assessments and set new priorities. The annual review considers audit outcomes, reported incidents, remediation success, training participation, and evolving regulatory expectations. We commit to continuous improvement, increased transparency and concrete actions to reduce the risk of modern slavery in our waste recycling, collection and processing activities, strengthening ethical supply chains for the long term.