Modern Slavery Statement — Commercial Waste Havering
This Modern Slavery Statement is published by Commercial Waste Havering to set out our commitment to combating modern slavery and human trafficking across our operations and supply chains. We recognise that commercial waste Havering operations carry intrinsic risks because of multi‑tiered contracting and labour supply, and we commit to transparent action to prevent exploitation.
We operate a clear zero-tolerance policy in relation to slavery, forced labour and human trafficking. All employees, contractors and subcontractors engaged in Commercial Waste - Havering activities must comply with this policy. Failure to adhere will result in disciplinary action, including contract termination where appropriate. Our aim is to ensure safe, fair and lawful working conditions across all Havering commercial waste services.
The policy applies to all parts of our business: front-line collection crews, recycling facilities, administrative staff and third-party partners. We require evidence of right-to-work, fair pay and safe working hours for anyone engaged in commercial waste collection Havering contracts. Regular risk mapping identifies high-risk roles and geographies and informs our targeted controls.
Supplier due diligence is central to how we prevent modern slavery. We conduct initial and ongoing supplier audits and risk assessments for all vendors providing goods or services to our company. Audit activities include:
- Review of recruitment and employment records
- On-site inspections and worker interviews
- Verification of payroll, hours and subcontracting arrangements
Our supplier audit programme prioritises high-risk partners in the Havering commercial waste services supply chain and those with complex labour models. We use a combination of desktop checks, remote assessments and physical audits, and we require corrective action plans where non-compliance is identified. Suppliers who refuse to engage or who fail to remediate will be removed from our approved supplier list.
We provide clear reporting channels for concerns relating to modern slavery. Staff and third parties can report issues through secure, anonymous mechanisms. Reports are handled in confidence and investigated promptly. Key features of our reporting process include independent investigation, protection for whistleblowers and escalation to senior management where warranted.
Prevention, Training and Continuous Improvement
To reduce the risk of exploitation, we invest in targeted training for employees and suppliers involved in commercial waste operations in Havering. Training covers recognising signs of modern slavery, the correct use of reporting channels, and the responsibilities of managers overseeing contracted staff. We also promote a culture where raising concerns is encouraged and supported.
Our performance metrics are designed to monitor effectiveness: number of audits completed, corrective actions closed, training completion rates and incidents reported. These metrics inform our continuous improvement cycle and ensure our people and partners align with the highest ethical standards for commercial waste services Havering.
We commit to an annual review of this statement and our practices. The review will evaluate policy effectiveness, audit outcomes and reporting trends, and will update procedures where necessary. Actions identified during the review will be assigned clear owners, timescales and measurable milestones.
Commitment and Governance
Leadership oversight is provided by the senior management team, who endorse our anti-slavery strategy and receive regular updates on progress. The following commitments summarise our approach:
- Zero tolerance of modern slavery across all operations
- Robust supplier audits and remediation processes
- Accessible and protected reporting channels for all stakeholders
- Annual review and continuous improvement of policies and practices
Through these measures Commercial Waste Havering seeks to reduce the risk of modern slavery in our business and supply chains. We will continue to strengthen our controls, collaborate with partners and maintain transparent governance to uphold the rights and dignity of all workers engaged in our commercial waste activities.