Anti-Slavery and Human Trafficking Policy

  1. Policy Statement

West & West Limited is committed to a zero-tolerance approach to modern slavery and human trafficking. We fully support the principles of the Modern Slavery Act 2015 and take proactive steps to ensure that slavery and human trafficking are not taking place in our business or within our supply chains.

This policy outlines the measures we have in place to prevent, detect, and respond to risks of modern slavery, and applies to all employees, contractors, suppliers, and business partners.

  1. Our Business and Structure

West & West Limited is a multi-award-winning electrical contracting company operating across the South-East of England. With a current turnover of approximately £5.3 million and a directly employed team of over 40 staff (as of June 2025), we work with a broad network of subcontractors, agencies, and suppliers.

  1. Our Supply Chain and Risk Management

We recognise that risks of modern slavery may arise within supply chains, particularly where labour-intensive practices are involved. While our suppliers are predominantly UK-based, we adopt a risk-based approach to managing our procurement and labour relationships.

To mitigate these risks, we:

  • Conduct ethical and compliance audits on key suppliers.
  • Require all new suppliers to complete a supplier prequalification questionnaire, including questions on modern slavery controls.
  • Include anti-slavery clauses in our supplier and subcontractor agreements.
  • Require evidence of compliance with the Modern Slavery Act from suppliers where appropriate.
  1. Due Diligence and Supplier Controls

As part of our procurement and supplier management process, we implement the following controls:

  • Supplier Approval Process: Incorporates ethical assessments and screening for modern slavery risks.
  • Ongoing Monitoring: Regular contact and annual reassessment of key suppliers through audits or questionnaires.
  • Contractual Requirements: Suppliers must confirm their compliance with anti-slavery legislation and provide policies on request.
  • Right to Audit: We reserve the right to audit suppliers where concerns are raised.
  1. Training and Awareness

To embed awareness of modern slavery risks:

  • Relevant employees (especially those in procurement, HR, and contract management) receive annual training.
  • The Modern Slavery Policy is included in onboarding and induction packs.
  • Refresher guidance is issued whenever this policy is updated.
  1. Reporting and Whistleblowing

We actively encourage the reporting of unethical behaviour and offer protection to whistleblowers. Mechanisms include:

  • Anonymous reporting via our internal whistleblowing process.
  • Clear reporting lines for staff who suspect slavery or trafficking.
  • Investigations led by senior management and escalation where necessary.
  1. Non-Compliance and Corrective Action

If any supplier or third party is found to be engaging in modern slavery practices:

  • We will provide written notification and set out required corrective actions.
  • If no remedial action is taken, or there is evidence of unwillingness to comply, we will terminate the relationship.
  • Serious cases will be reported to relevant authorities.
  1. Monitoring, Review and Improvement

To evaluate the effectiveness of our approach, we:

  • Review and update this policy annually.
  • Monitor supplier compliance and issues raised.
  • Track training completion rates.
  • Audit the use of temporary labour and agency workers.
  1. Supporting Policies

This policy is supported by the following internal documents:

  • Purchasing and Procurement Policy
  • Grievance Policy
  • Whistleblowing Policy
  • Equality, Diversity and Inclusion Policy
  • Code of Conduct
  1. Policy Ownership

This policy is owned by the Board of Directors. Responsibility for its implementation rests with senior management, supported by our Procurement and HR teams.