Modern Slavery Statement — Commercial Waste Richmond upon Thames
Commercial Waste Richmond upon Thames is committed to preventing modern slavery and human trafficking in any form within our operations and supply chain. This Modern Slavery Statement explains our zero-tolerance policy, our approach to due diligence, and the measures we take across the Richmond upon Thames commercial waste sector. We unequivocally reject exploitation and forced labour and require the same high standards from our suppliers and subcontractors.
Our statement applies to all activities performed by the business, including refuse collection, transfer, recycling and disposal services provided to businesses and organisations across the borough. The policy covers permanent and temporary staff, contractors and anyone working on behalf of our commercial waste services in Richmond. We expect partners and suppliers to adhere to laws and international standards aimed at eliminating exploitation and coercion from the industry.
This document sets out how Commercial Waste — Richmond upon Thames identifies and mitigates modern slavery risk. Our zero-tolerance policy means any confirmed instance of forced labour or human trafficking will lead to contract termination and remedial action. We define modern slavery broadly to include servitude, bonded labour, human trafficking and any form of coercion that undermines individual autonomy and dignity.
Supplier Expectations and Audit Programme
We require all suppliers for Richmond upon Thames commercial waste contracts to meet our mandatory standards. Procurement criteria explicitly include compliance with labour standards and transparent employment practices. Our supplier code of conduct requires suppliers to provide evidence of:
- Legal right to work and fair contracts for employees;
- Reasonable working hours and wages;
- Safe working conditions and freedom from coercion.
We operate a risk-based audit regime for our waste supply chain. Supplier audits combine document checks, site visits and, where appropriate, worker interviews. High-risk suppliers receive enhanced scrutiny, and we reserve the right to perform unannounced audits. Records of audits, corrective actions and follow-up are maintained to monitor compliance and continual improvement across the commercial waste services Richmond market.
Training is provided to procurement staff and contract managers to identify indicators of modern slavery. Our procurement teams use contract clauses that permit supplier inspection and remediation. If a supplier fails to remediate promptly, we will pursue contract termination and seek to mitigate harm to affected workers.
Reporting Channels and Responsible Escalation
We maintain multiple confidential reporting channels for concerns regarding exploitation, trafficking or forced labour within our operations or supply chain. Reports can be raised internally through designated safeguarding officers or anonymously via established whistleblowing mechanisms. All allegations are treated seriously, investigated promptly and escalated to senior management as needed. The reporting process protects whistleblowers from retaliation and emphasises the welfare of any worker at risk.
Our investigative process includes:
- Timely risk assessment of reported incidents;
- Immediate protective steps for affected individuals;
- Engagement with external agencies where required, while respecting legal confidentiality obligations.
Monitoring, Review and Continuous Improvement: We maintain records of due diligence activities, audit results and corrective actions to demonstrate compliance and drive improvement across CW Richmond upon Thames operations. Senior leadership reviews modern slavery risks as part of governance oversight, and we incorporate lessons learned into procurement practices and staff training. Our commitment to transparency means we will update policies and supplier requirements to reflect evolving best practice.
We commit to an annual review of this Modern Slavery Statement and associated policies. The annual review assesses the effectiveness of our audit programme, reporting channels and remedial actions, and identifies enhancements to our approach. Through regular review and targeted supplier engagement, we aim to reduce the risk of modern slavery in the commercial waste supply chain across Richmond upon Thames.
Statement of Intent: Commercial Waste Richmond upon Thames will continue to uphold strong ethical standards, work collaboratively with partners and take decisive action where modern slavery risks are identified. We believe that protecting the rights and dignity of workers is fundamental to responsible service delivery in the borough's commercial waste sector.
