Modern Slavery Statement — Commercial Waste Downham

Commercial Waste Downham (often referred to as CWD) confirms its commitment to preventing modern slavery and human trafficking across all operations. This statement sets out the steps taken during the reporting period, underlining a zero-tolerance policy towards any form of forced labour, servitude, or exploitation in our supply chain and service delivery. We acknowledge our responsibility as a provider of commercial waste services Downham and commit to robust actions to reduce risk.

Our Policy and Principles

We maintain a clear, written policy that outlines expectations for all employees, contractors and suppliers. The policy emphasises that exploitation will not be tolerated and that any credible allegations will be investigated. This policy applies across our operations, including agency labour, subcontractors and procurement for waste management Downham activities. We require compliance with applicable laws and expect partners to adopt equivalent standards.

Zero-Tolerance Approach and Reporting

Our zero-tolerance policy is enforced through contractual clauses, pre-engagement checks and ongoing monitoring. Anyone who becomes aware of suspected modern slavery is encouraged to raise concerns through our multiple reporting channels. Reporting channels include anonymous internal reporting routes and secure escalation paths. We protect whistleblowers from retaliation and treat reports seriously, ensuring prompt risk assessment and remedial action when necessary.

Supplier Audits and Due Diligence

We perform risk-based supplier audits and due diligence to verify compliance among our supply chain partners. Our audit programme focuses on high-risk suppliers and those involved in labour-intensive services. Audits combine desk-based checks with on-site inspections and review of employment records. If non-compliance is identified, we require corrective action plans, and may suspend or terminate relationships where necessary.

Audit measures include:

• Verification of legal right to work documentation and wage records;
• Review of recruitment practices and third-party labour suppliers;
• Interviews with workers to assess working conditions and freedom of movement;
• Contractual clauses requiring adherence to anti-slavery standards and termination rights for breaches.

Reporting channels are supported by training for managers and procurement teams so that concerns raised during audits are escalated appropriately. We also maintain records of audit outcomes and remediation progress and ensure lessons learned inform supplier selection and contract management.

Training and Awareness — We deliver targeted training to all staff involved in procurement, contract management and field operations. Training covers recognition of exploitation indicators, how to use reporting channels, and how to conduct due diligence for Downham commercial waste contracts. We also require periodic refresher training to keep awareness high and to embed a culture of vigilance.

Our commercial waste services Downham approach integrates modern slavery risk management into normal business processes. We update contract templates to include modern slavery clauses, require suppliers to provide evidence of compliance, and include anti-slavery obligations in tender evaluations. We also use risk mapping to prioritise sectors and regions of concern within our operational footprint.

Annual Review and Continuous Improvement — We undertake an annual review of our anti-slavery activities to assess effectiveness and identify improvements. This review evaluates policy implementation, audit outcomes, training reach, and the use of reporting channels. Findings are used to strengthen controls, refine supplier audit frequency, and update risk assessments. Our board and senior management receive a formal report on progress and approve the annual action plan.