Modern Slavery Policy

Modern Slavery & Human Trafficking Policy

HVW LTD is committed to ensuring that all business operations, supply-chain activities and organisational practices actively prevent modern slavery, forced labour and human trafficking.

We take a zero-tolerance approach to exploitation and work continually to promote transparency, ethical sourcing and responsible business conduct.

Our Ethical Commitment

We work to safeguard workers, protect human rights and support responsible sourcing across our business and supply chain.

  • Zero tolerance for exploitation
  • Supplier due diligence
  • Risk assessment and monitoring
  • Whistleblowing and reporting procedures
  • Annual policy review
Zero Tolerance approach to modern slavery
2015 Modern Slavery Act alignment
Annual Policy review and updates
Safe Reporting and whistleblowing route

Our Commitment

We ensure that our supply chain, operations and employment practices are aligned with UK legislation, including the Modern Slavery Act 2015. Our goal is to safeguard workers, protect human rights and ensure full compliance with ethical labour standards.

  • High ethical standards across all business operations.
  • Promotion of Fair Trade, Sustainability and Human Rights.
  • Robust recruitment processes including eligibility-to-work checks.
  • Whistleblowing procedures enabling staff to report concerns safely.
  • Clear expectations for staff and suppliers via our Code of Conduct.

Supplier Due Diligence

We monitor existing suppliers and assess new suppliers to ensure that labour exploitation is not present within our supply chain.

  • Mapping the supply chain to understand labour and sourcing risks.
  • Conducting supplier audits and assessments where required.
  • Identifying high-risk areas and implementing corrective actions.
  • Educating suppliers on best practices for eliminating modern slavery.
  • Participating in collaborative initiatives and industry discussions.

Risk Assessment & Management

Before onboarding or renewing supplier relationships, we evaluate the risks associated with geographic location, industry category, labour practices and subcontracting activity.

  • Identify potential vulnerabilities.
  • Assess the level of severity and likelihood.
  • Introduce and enforce appropriate control measures.
  • Monitor improvements and ensure corrective actions are sustained.

Monitoring & KPI Performance

We regularly review our activities and measure performance against defined modern slavery objectives.

Annual summaries and policy updates will be made available upon request or published on our website in accordance with transparency requirements.

HVW LTD will continue to review its supplier controls, reporting processes and training activity to support ongoing improvement.

Training & Awareness

Training is provided to employees, contractors and relevant stakeholders to ensure that modern slavery awareness is embedded within HVW LTD.

  • Induction training and policy acknowledgement.
  • Toolbox talks and internal workshops.
  • Relevant online training modules.
  • Seminars and industry events for managers and at-risk staff.

All training progress is recorded and monitored through our internal KPI systems.

Roles & Responsibilities

HVW LTD Responsibilities

  • Maintain and update this Modern Slavery Policy.
  • Identify and address modern slavery risks.
  • Provide training and information to all relevant employees.
  • Ensure supplier and contractor compliance with this policy.
  • Continuously improve processes and controls.

Employee Responsibilities

  • Follow company policies relating to modern slavery and human trafficking.
  • Participate in training and awareness activities.
  • Report concerns to senior management immediately.
  • Maintain compliance with the Whistleblowing Policy.

Whistleblowing & Reporting Concerns

HVW LTD encourages employees and partners to report any suspected human trafficking or modern slavery in the business or supply chain.

Reports can be made confidentially without fear of reprisal and will be investigated thoroughly.

Any suspected modern slavery, forced labour, human trafficking or exploitation concern should be reported to senior management as soon as possible.

Policy Review

This statement is reviewed annually or following significant changes in legislation, supply-chain structure or business operations.

Updates are published to maintain full transparency.

Signed Statement

This Modern Slavery & Human Trafficking Policy has been approved by HVW LTD and is reviewed as part of our ongoing commitment to ethical sourcing and responsible business conduct.

John McCarrick Managing Director HVW LTD Date: 10/10/2025