Commercial Waste Blackfriars Modern Slavery Statement
This Modern Slavery Statement describes the policies, systems and controls that Commercial Waste Blackfriars has in place to ensure that modern slavery and human trafficking does not take place in our business or supply chains. We recognise our responsibility as a provider of waste services in the local area and across the wider service network. Our commitment to ethical labor standards underpins every contract and operational decision made by the Blackfriars commercial waste team.
We operate a zero-tolerance policy towards modern slavery, forced labour and any form of exploitation. That zero-tolerance approach means that any credible allegation will trigger immediate action, which can include suspension of contracts, termination of supplier relationships and referral to the appropriate authorities. The policy is communicated clearly to employees, contractors and partners and forms part of our procurement and on-boarding requirements for waste contractors operating under the commercial waste in Blackfriars banner.
The scope of this statement includes all companies and individuals that provide goods or services to Commercial Waste Blackfriars, including subcontractors and third-party suppliers. We take a risk-based approach to identifying where modern slavery might occur, prioritising higher-risk segments of our supply chain such as manual collection crews, temporary labour and key logistics operations. Our aim is to ensure the integrity of the Blackfriars waste services supply chain through transparent standards and continued oversight, and to underline that exploitation is not tolerated.
Supplier Audits and Due Diligence
Supplier audits are central to our prevention strategy. We conduct pre-contract risk assessments, contractual supply chain assurances and on-site compliance checks. Audit activities include documentary verification, worker interviews and site inspections where appropriate. We document findings and require remediation plans for any non-conformance. The commercial-waste Blackfriars procurement team is authorised to suspend services where remediation is insufficient or where immediate safeguards are required to protect workers.
Audits are scheduled based on risk profile and prior compliance history. High-risk suppliers receive more frequent checks and may be subject to third-party verification. We use a combination of internal audit resources and independent auditors to maintain impartial oversight. Where audits reveal potential exploitation, we deploy rapid response measures and collaborate with relevant agencies and stakeholders to ensure the safety and rights of affected workers are restored. This approach strengthens our ability to detect and prevent modern slavery across the Blackfriars commercial waste network.
We provide clear contractual obligations to suppliers that require adherence to our anti-slavery standards and allow for audit and termination where necessary. Continuous improvement is driven by corrective action plans and by incorporating lessons learned into supplier selection and contract management.
Reporting Channels, Training and Annual Review
We maintain accessible reporting channels for employees, contractors and third parties to raise concerns confidentially. Reporting channels include anonymous hotlines, internal whistleblowing processes and designated compliance contacts within our organisation. All reports are treated seriously and investigated promptly. We ensure protection for whistleblowers and confidentiality where appropriate, reinforcing our stance that anyone raising concerns will face no retaliation.
Training and awareness are essential. Staff involved in procurement, contract management and operational supervision receive targeted training on modern slavery risks, recognition of indicators and the correct steps to escalate issues. We also require that critical suppliers provide evidence of training for their relevant personnel. This training underpins our practical response to suspected incidents and builds capability across the commercial waste in Blackfriars ecosystem.
An annual review of this Modern Slavery Statement and our associated policies is conducted by senior management and reported to the executive leadership team. The annual review evaluates the effectiveness of our measures, the results of supplier audits, the volume and nature of reports received through reporting channels, and the progress of remedial actions. Where necessary, policies and operational controls are updated and redeployed to ensure continuous improvement. Commercial Waste Blackfriars reaffirms its commitment to ethical supply chains, to eradication of modern slavery from our activities, and to transparent, accountable governance of our Blackfriars waste management operations.
