Modern Slavery and Human Trafficking Policy

1. Policy Statement

Modern slavery is a crime and a grave violation of fundamental human rights. It manifests in slavery, servitude, forced labour, and human trafficking, all of which involve the deprivation of liberty for personal or commercial exploitation.

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At Thomas Charles Facilities & Maintenance, we maintain a zero-tolerance approach to modern slavery within our business and supply chains. We are committed to acting ethically, enforcing effective controls, and ensuring modern slavery does not occur in any part of our organization.

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2. Responsibilities & Awareness

We recognize our duty to:

·         Educate and support staff in identifying and addressing modern slavery and human trafficking.

·         Encourage employees to report concerns through designated channels without fear of reprisal.

·         Assist and safeguard individuals affected by modern slavery by liaising with specialized services.

·         Ensure compliance at all levels, with line managers enforcing this policy in daily operations.

All employees who suspect modern slavery must report their concerns to their line manager or supervisor.

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3. Reporting & Escalation Procedures

Victims of modern slavery may not self-identify, often presenting with unrelated issues. If a concern arises, the following steps must be taken:

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1.      Identifying a concern – This may involve direct reports or observations of exploitation.

2.      Immediate danger – If an individual is at risk, the police must be notified via 999.

3.      Internal escalation – Concerns should be discussed with a line manager where appropriate.

4.      Company response – High-level management will escalate matters to relevant authorities and specialized services.

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4. Safer Recruitment & Supply Chain Management

To mitigate risks, Thomas Charles Facilities & Maintenance ensures:

·         Thorough recruitment procedures, including Enhanced DBS checks, identity verification, and right-to-work confirmation.

·         Strict supplier due diligence, ensuring ethical sourcing and compliance with anti-slavery regulations.

·         Ongoing monitoring, particularly for imported goods from high-risk regions.

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5. Employee Training & Education

All employees receive training on modern slavery and human trafficking, including indicators such as:

·         Unpaid wages or financial exploitation.

·         Restricted movement (e.g., passport confiscation).

·         Forced labour or coercion for financial or sexual gain.

·         Individuals living and working at the same address.

Staff are required to report concerns either internally to their manager or externally to law enforcement.

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6. Health & Safety of Workers

We commit to implementing local and national government policies to protect workers throughout our supply chain.

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7. Review & Compliance

To ensure ongoing effectiveness, we will:

·         Monitor risk areas within our supply chains.

·         Support employees in recognizing and preventing modern slavery.

·         Ensure all staff have access to training on victim identification.

·         Integrate modern slavery considerations into our safeguarding policies.

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8. Policy Commitment & Transparency

Thomas Charles Facilities & Maintenance actively works to eliminate modern slavery and human trafficking. We acknowledge our responsibility under the Modern Slavery Act 2015 and remain committed to transparency in our practices.

·         Supplier approval processes incorporate ethical risk assessments.

·         High-risk imports receive enhanced scrutiny.

·         No business knowingly involved in modern slavery will be engaged.

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Our Directors and Senior Management take responsibility for implementing this policy and providing necessary resources to ensure compliance.

This policy is reviewed annually and published internally. A full copy is available via the HR department upon request.​