Modern Slavery Statement for Commercial Waste Soho
Commercial Waste Soho is committed to eliminating all forms of forced labour, human trafficking and exploitation. This Modern Slavery Statement sets out our approach and expectations across our business and supply chain. Our zero-tolerance stance is clear: we will not tolerate modern slavery in any part of our operations or among our contractors and suppliers.
Our Policy and Commitment
We operate a zero-tolerance policy on slavery and human trafficking. The commercial waste modern slavery statement applies to every employee, contractor and partner involved with Commercial Waste Soho. We expect partners to share our standards and to act with integrity. All procurement and project decisions consider ethical and human-rights impacts alongside commercial criteria.
Due Diligence and Risk Assessment
As part of our ongoing modern slavery due diligence, we map our supply chain, identify high-risk areas and review subcontracting arrangements. Our risk assessments focus on sectors and geographies known to be vulnerable to exploitation. The CWS modern slavery programme uses a combination of documentary checks, third-party intelligence and local risk indicators to prioritise audits.
Supplier Audits and Monitoring
We will implement targeted supplier audits and site visits for high-risk suppliers. These audits include verification of employment records, working conditions and recruitment practices. Where issues are identified we require corrective action plans and follow-up reviews. Our audit approach is pragmatic: we combine scheduled checks with random sampling and escalate persistent non-compliance to contractual remedies, up to and including termination of supply.
Standards, Training and Expectations
All staff and contractors receive training on the modern slavery statement and their role in prevention. Training covers recognising signs of exploitation, reporting mechanisms and supplier engagement. We set clear contractual standards for suppliers that include compliance with labour laws, prohibition of forced labour and transparent recruitment practices. Our procurement teams include slavery risk clauses in relevant contracts.
We support suppliers to improve through capacity building and share best practice for safeguarding workers. Where suppliers demonstrate willingness to remediate, we provide a structured time-bound plan. For suppliers who refuse to act or where remediation is not possible, we reserve the right to cease business relationships.
Reporting Channels and Whistleblowing
Reporting channels are available to employees and third parties to raise concerns confidentially and without fear of retaliation. Multiple routes are provided, including anonymous reporting mechanisms and internal escalation to designated compliance officers. We investigate all credible reports promptly, maintain confidentiality where possible, and take proportionate action. Anyone reporting suspected exploitation will be treated with respect and supported through the process.
Continuous Improvement and Collaboration
Commercial Waste Soho recognises that preventing modern slavery requires ongoing effort. We engage with industry partners, NGOs and local stakeholders to improve labour standards across the commercial waste sector. Our procurement practices encourage suppliers to demonstrate continual improvement and transparency in their labour supply chains.
Annual Review and Governance
Our Board reviews this modern slavery policy and the broader CWS modern slavery statement annually. The review covers audit outcomes, remediation actions, training efficacy and emerging risks. We update policies and controls as needed and report on progress internally. This annual review ensures governance oversight and accountability for eradicating modern slavery from our operations.
Summary of Key Measures:
- Zero-tolerance policy clearly communicated across the organisation.
- Risk-based supplier audits and corrective action plans.
- Multiple, confidential reporting channels and whistleblowing protections.
- Training, capacity building and collaboration with external stakeholders.
- Annual review and continuous improvement overseen by senior management.
Through this commercial waste modern slavery statement, Commercial Waste Soho reaffirms its commitment to ethical operations, the protection of workers and the eradication of modern slavery from our industry. We will continue to strengthen our controls, hold suppliers to account and ensure that the rights and dignity of every worker are respected across our value chain.
