Modern Slavery Statement — Commercial Waste Spitalfields

This Modern Slavery Statement sets out the commitment of Commercial Waste Spitalfields and affiliated teams to prevent modern slavery and human trafficking in our operations and supply chain. Our policy reflects a zero-tolerance approach to any form of forced labour, servitude or exploitation in the provision of commercial waste services and Spitalfields refuse management. We recognise the responsibility that comes with managing commercial waste in Spitalfields and are committed to clear, effective action.

We operate a formal zero-tolerance policy which prohibits any practice that could amount to modern slavery, whether within our direct workforce, subcontractors or suppliers who support our Spitalfields commercial waste operations. The policy is owned at board level and implemented across the organisation by management teams, contract managers and procurement staff. It is applied equally to all categories of workers, including temporary staff, agency labour and contractors engaged in CW Spitalfields activities.

Our approach to preventing modern slavery combines risk assessment, targeted supplier engagement and routine audits. We maintain a risk register for areas of our business where commercial waste Spitalfields activity could be vulnerable, and apply proportionate mitigation measures to reduce exposure to exploitation. The risk assessment process considers the sector, geography, workforce demographics and the nature of services provided.

We carry out supplier audits as a core control to verify compliance across the supply chain. Audit activity includes desktop checks, on-site visits and documentation reviews to confirm fair labour practices and lawful worker documentation. Where audits identify non-conformances, we require corrective action plans with defined timescales and follow-up checks until satisfactory remediation is achieved.

Supplier due diligence and audit framework

Our supplier due diligence for Spitalfields commercial waste contractors is risk-based and includes:

• Initial vetting: verification of company credentials, licences and insurance for commercial waste services;
• Contractual clauses: mandatory modern slavery compliance clauses and the right to audit;
• Periodic audits: scheduled and ad hoc audits focused on workforce welfare, pay and working conditions;
• Remediation: clear expectations for corrective action and escalation for persistent breaches.

In addition to supplier audits, we provide training to staff and managers involved in procurement and contract oversight on how to spot indicators of modern slavery. Training covers the specific risks associated with commercial waste in Spitalfields, such as subcontracted manual labour, transient workforces and informal recruitment channels. We use a mix of classroom sessions, digital modules and scenario-based learning to maintain awareness across teams.

Reporting channels and protection for reporters

We maintain confidential reporting channels that enable employees, contractors and third parties to raise concerns safely and without fear of retaliation. Reports can be made through internal whistleblowing procedures, via line management or through independently managed channels. All reports are taken seriously, investigated promptly and handled in line with our disciplinary and safeguarding policies. We provide support measures for vulnerable individuals and ensure protection for whistleblowers.

Investigations follow a documented process which includes initial assessment, risk mitigation for affected individuals, formal investigation and, where appropriate, disciplinary or contractual action against perpetrators or negligent suppliers. Outcomes of investigations inform continuous improvement, supplier selection and contract management practices for CW Spitalfields projects.

The statement and our policies are subject to an annual review to ensure they remain effective and reflect evolving legislation, best practice and operational changes. The review process is led by senior management, informed by audit findings, incident reports and feedback from site teams involved in day-to-day commercial waste operations in Spitalfields.

Key performance indicators are used to monitor progress, including the number of supplier audits completed, the proportion of suppliers with corrective action plans, training completion rates and the number of reports raised and resolved. We publish an annual summary of actions taken and improvements made to strengthen transparency and accountability within our Spitalfields commercial waste supply chain.

In conclusion, Commercial Waste Spitalfields remains firmly committed to eradicating modern slavery from our operations and supply chain. We will continue to apply a robust, risk-based approach — combining rigorous supplier audits, clear reporting channels, comprehensive training and an annual review cycle — to protect workers and uphold the highest ethical standards across all our commercial waste and Spitalfields refuse services.