Modern Slavery and Human Trafficking Statement

Waste Collection Canary Wharf is committed to conducting all aspects of our business ethically, with integrity and in full compliance with applicable laws. This Modern Slavery and Human Trafficking Statement sets out the steps we take to prevent modern slavery and human trafficking in our operations and supply chains. It applies to all employees, contractors, suppliers, and business partners engaged with Waste Collection Canary Wharf.

Our Zero-Tolerance Approach

We operate a zero-tolerance policy towards all forms of modern slavery, human trafficking, forced labour, and child labour. We will not knowingly work with any organisation or individual that engages in, condones, or is complicit in such practices. Our senior management is responsible for ensuring that this commitment is embedded into our culture, policies, and day-to-day decision making. All employees are required to act in a manner that supports this stance and to report any concerns immediately.

Governance and Responsibility

Overall responsibility for this statement rests with the board and senior leadership of Waste Collection Canary Wharf. Operational responsibility for implementing and monitoring our anti-slavery measures sits with our compliance and procurement functions. Managers at all levels are responsible for ensuring those reporting to them understand and comply with this statement and the supporting policies and procedures. We make clear in our internal codes of conduct that modern slavery will not be tolerated under any circumstance.

Risk Assessment and Due Diligence

We recognise that the waste management sector and associated services can be exposed to modern slavery risks, particularly where manual labour, subcontracting, or temporary staffing is involved. We review our operations and supply chains to identify higher-risk areas, such as labour-intensive services, vehicle maintenance, equipment supply, and facilities management. Where higher risks are identified, we apply enhanced due diligence, including closer scrutiny of labour practices, recruitment processes, and subcontracting structures.

Supplier Standards and Audits

All suppliers, contractors, and service providers are expected to comply with our standards on labour and human rights. We communicate our zero-tolerance approach and require confirmation that they do not use forced, trafficked, or child labour. We incorporate modern slavery provisions into our contractual terms where appropriate. We undertake supplier audits proportionate to the level of risk, which may include reviewing documentation, interviewing management, and, where feasible, site visits. Where non-compliance is identified, we expect prompt corrective action. Failure to address serious or repeated issues may result in suspension or termination of the business relationship.

Training and Awareness

We provide training and guidance to relevant staff, particularly those in procurement, operations, and human resources, to help them understand the signs of modern slavery and how to respond to concerns. Induction and refresher training emphasise our zero-tolerance policy, the importance of ethical sourcing, and the procedures for escalating issues. We aim to foster a culture where human rights are respected and where employees feel empowered to speak up.

Reporting Channels and Protection

We encourage anyone who becomes aware of, or suspects, any form of modern slavery connected to our operations or supply chain to raise their concerns at the earliest opportunity. Concerns can be reported to line managers, senior management, or through confidential internal reporting channels. Reports will be treated seriously, investigated promptly, and handled sensitively. No individual who raises a concern in good faith will suffer detriment, victimisation, or retaliation as a result of speaking up.

Continuous Improvement and Annual Review

We are committed to continually improving our approach to combating modern slavery. This includes reviewing our policies, due diligence processes, training materials, and supplier oversight arrangements. We monitor developments in legislation and best practice to ensure our processes remain effective and proportionate to the risks we face. This statement is reviewed at least annually by senior management to assess its effectiveness and to identify areas for enhancement. Any significant changes in our structure, operations, or supply chains will trigger an interim review. Following each review, updates to this statement and related procedures will be communicated internally and to relevant external stakeholders as appropriate.

This Modern Slavery and Human Trafficking Statement has been approved by the leadership of Waste Collection Canary Wharf and reflects our ongoing commitment to preventing modern slavery in all areas of our business.