Modern Slavery and Human Trafficking Policy

1. Our commitment

SiteVera is committed to conducting business ethically, responsibly and with respect for human rights.

We have zero tolerance for slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, exploitative recruitment or any other form of modern slavery within our business or supply chain.

We are committed to taking proportionate and practical steps to identify, prevent and address modern-slavery risks associated with our operations, employees, agency workers, subcontractors and suppliers.

This policy reflects the principles of the Modern Slavery Act 2015 and applies whether or not SiteVera is legally required to publish an annual statement under section 54 of the Act.

2. About SiteVera

SiteVera provides professional grounds maintenance, landscaping and site-management services to schools, colleges, local authorities and commercial organisations.

Our activities may involve employees, agency labour, subcontracted specialists, plant and material suppliers, equipment providers, waste contractors and other service partners.

We recognise that modern-slavery risks can arise within businesses of every size and may be present at different stages of a supply chain.

3. Scope

This policy applies to:

  • All SiteVera employees and workers

  • Directors and managers

  • Temporary and agency workers

  • Consultants

  • Subcontractors

  • Suppliers

  • Labour providers

  • Other organisations working on SiteVera’s behalf

Everyone covered by this policy is expected to act honestly, raise concerns and support SiteVera’s commitment to preventing exploitation.

4. What is modern slavery?

Modern slavery includes situations where an individual is exploited and cannot freely refuse or leave because of threats, coercion, deception, abuse of power or financial control.

It can include:

  • Slavery and servitude

  • Forced or compulsory labour

  • Human trafficking

  • Debt bondage

  • Exploitative recruitment

  • Retention of identity documents

  • Restriction of movement

  • Threats or intimidation

  • Withholding wages

  • Charging workers recruitment fees

  • Abuse of vulnerable, migrant or temporary workers

Modern slavery may not always be immediately visible. Warning signs can include individuals appearing frightened, controlled, underpaid, dependent on another person or unable to access their own documents or wages.

5. Responsibilities

The Director has overall responsibility for this policy and for ensuring SiteVera maintains appropriate arrangements for preventing modern slavery.

Managers are responsible for:

  • Applying this policy within their areas of responsibility

  • Completing appropriate supplier and subcontractor checks

  • Remaining alert to warning signs

  • Responding appropriately to concerns

  • Escalating suspected breaches promptly

All employees and workers are responsible for:

  • Reading and following this policy

  • Treating colleagues and workers fairly

  • Remaining alert to possible exploitation

  • Reporting concerns without delay

  • Cooperating with investigations

6. Recruitment and employment

SiteVera is committed to fair, transparent and lawful recruitment practices.

We will:

  • Confirm that workers have the legal right to work

  • Provide clear information about employment terms and pay

  • Comply with applicable wage, working-time and employment requirements

  • Avoid the use of recruitment arrangements that create worker debt

  • Not charge workers recruitment fees

  • Not retain passports or personal identity documents

  • Not require workers to lodge deposits as a condition of employment

  • Ensure workers are free to leave employment subject to lawful contractual notice

  • Take proportionate steps to check labour agencies before appointment

  • Investigate signs that a worker may be controlled, threatened or exploited

Where agency labour is used, SiteVera may request evidence regarding recruitment methods, pay arrangements, right-to-work checks and worker-welfare procedures.

7. Suppliers and subcontractors

SiteVera expects suppliers and subcontractors to share our commitment to ethical working practices.

Our risk-based due-diligence process may include:

  • Confirming the supplier’s identity and ownership

  • Reviewing relevant policies and procedures

  • Checking employment and recruitment practices

  • Reviewing the use of agency or temporary labour

  • Requesting evidence of right-to-work processes

  • Reviewing insurance, accreditation and compliance information

  • Including modern-slavery requirements in contracts

  • Requiring standards to be passed through relevant supply chains

  • Investigating concerns or inconsistencies

  • Monitoring higher-risk suppliers more closely

Suppliers and subcontractors must not knowingly use forced, trafficked or exploited labour.

They must notify SiteVera promptly if they identify actual or suspected modern slavery connected to any service, product or supply chain supporting SiteVera.

8. Risk areas

SiteVera will take a proportionate approach to identifying and managing risk.

Areas that may require additional attention include:

  • Temporary, seasonal or agency labour

  • Labour-intensive subcontracted services

  • Complex or unclear subcontracting arrangements

  • Recruitment of migrant workers

  • Plant and horticultural supply chains

  • Imported landscaping materials

  • Workwear and personal protective equipment

  • Equipment and machinery supply chains

  • Waste-management and transport services

  • Suppliers operating in higher-risk locations

Risk will be considered when appointing new suppliers and during the management of existing contracts.

9. Reporting concerns

Anyone who believes that modern slavery may be occurring within SiteVera or its supply chain should report the concern immediately.

Concerns can be reported to:

The Director
Email: [INSERT COMPLIANCE EMAIL]
Telephone: [INSERT TELEPHONE NUMBER]

Reports will be treated seriously and handled as confidentially as reasonably possible.

No employee or worker will suffer retaliation or detrimental treatment for raising a genuine concern in good faith, even if an investigation later finds that no breach occurred.

Knowingly making a false or malicious allegation may be treated as a disciplinary matter.

10. Responding to suspected modern slavery

Where a concern is identified, SiteVera will take appropriate action based on the nature and severity of the risk.

This may include:

  • Protecting the immediate safety and welfare of affected individuals

  • Escalating the matter to senior management

  • Preserving relevant information

  • Conducting an internal investigation

  • Seeking professional advice

  • Cooperating with competent authorities

  • Requiring corrective action from a supplier

  • Increasing monitoring and assurance

  • Suspending work or appointments

  • Terminating a supplier or subcontractor relationship

  • Reviewing controls to prevent recurrence

Our response will prioritise the safety and interests of potentially affected individuals. Ending a contract will not automatically be the first response where doing so could worsen the position of vulnerable workers.

11. Breaches of this policy

A breach of this policy by an employee may result in disciplinary action, including dismissal where appropriate.

A breach by a supplier, subcontractor or other business partner may result in corrective-action requirements, suspension or termination of the commercial relationship.

Serious concerns may be reported to the relevant authorities.

12. Training and awareness

SiteVera will provide proportionate information and training to individuals whose roles involve:

  • Recruitment

  • Supplier appointment

  • Subcontractor management

  • Contract management

  • Site supervision

  • Procurement

  • Worker welfare

Training and guidance will focus on recognising warning signs, reporting concerns and applying appropriate supply-chain checks.

13. Monitoring

SiteVera will monitor the effectiveness of this policy through measures appropriate to the size and nature of the business.

These may include:

  • Supplier and subcontractor checks completed

  • Higher-risk suppliers reviewed

  • Concerns raised and investigated

  • Corrective actions completed

  • Relevant staff receiving guidance or training

  • Contract clauses implemented

  • Changes in operational or supply-chain risk

SiteVera will continually review and strengthen its approach as the business and supply chain develop.

14. Annual statement

Where SiteVera becomes legally required to publish an annual modern-slavery statement under section 54 of the Modern Slavery Act 2015, we will prepare, approve and publish a statement in accordance with the applicable requirements.

SiteVera may also publish a voluntary statement where this supports transparency or client and procurement requirements.

15. Review and approval

This policy will be reviewed at least annually and following any significant change to:

  • Applicable legislation or guidance

  • SiteVera’s services

  • Workforce arrangements

  • Supply chains

  • Identified modern-slavery risks