Modern Slavery Statement — Commercial Waste Luton

This statement sets out the enduring commitment of Commercial Waste Luton and its affiliates to prevent modern slavery and human trafficking throughout our operations and supply chain. We recognise the risks associated with waste management and refuse services and confirm that we operate a zero-tolerance policy towards any form of forced labour, servitude or exploitation.

Our policy applies to all employees, contractors and suppliers engaged in providing commercial waste services in Luton and surrounding areas. We aim to align our approach with good practice in the sector and to ensure that our procurement, monitoring and contracting arrangements reduce the risk of modern slavery in Luton commercial waste operations.

We maintain a clear zero-tolerance policy on modern slavery. Any instance of suspected exploitation is taken seriously: allegations are investigated promptly and robust action is taken where breaches are identified, including termination of contracts with non-compliant suppliers. Our leadership team and board provide oversight and support resources to ensure consistent enforcement.

Our approach to prevention and due diligence

We adopt a risk-based approach to due diligence across the entire commercial waste supply chain. Our process combines pre-engagement screening, ongoing monitoring and corrective action. As a provider of commercial waste services Luton businesses rely upon, we prioritise transparency, traceability and supplier accountability.

Key elements include:

• Supplier audits: scheduled and unannounced audits to assess working conditions and compliance;
• Contractual clauses: clear anti-slavery obligations in all supplier contracts;
• Training and awareness: staff and procurement teams receive regular training on identifying risks and reporting concerns.

Supplier audits and monitoring

Supplier audits form a central pillar of our mitigation strategy. We conduct documented assessments of high-risk suppliers, using third-party auditors where appropriate, and require corrective action plans for identified issues. Our audit programme for ComWaste Luton includes checks on recruitment practices, wage verification, working hours, and the right to work documentation.

We encourage whistleblowing through multiple reporting channels. Employees, contractors and third parties can raise concerns internally through our confidential reporting mechanisms, and any report is treated with strict confidentiality. We ensure that those raising concerns are protected from retaliation and that issues are escalated to senior management for action.

Reporting channels are supported by clear procedures for investigation and remediation. Our approach balances prompt fact-finding with support for any affected individuals. In circumstances where supply chain partners are implicated, we work to remediate harm and, where necessary, terminate relationships to protect workers and the integrity of the Luton commercial waste sector.

We maintain records of all reports, investigations and outcomes and use those data to improve risk assessments and supplier engagement strategies. This continuous improvement loop is critical to reducing the incidence of modern slavery in commercial waste collection and disposal activities.

Governance and annual review: our board and senior management review anti-slavery governance each year. This annual review ensures policies remain effective and aligned with evolving risks. The review covers our supplier audit results, remediation outcomes, training completion rates and any legislative changes that affect the sector.

We require our suppliers to commit to ethical labour standards and to cooperate with audits and remediation where issues are found. For serious breaches, we will suspend or end contracts. We also collaborate with industry partners, local authorities and specialist organisations to strengthen protections across the wider waste management ecosystem.

In conclusion, Commercial Waste Luton reaffirms its commitment to eradicating modern slavery and human trafficking from our operations and supply chains. Through robust supplier audits, accessible reporting channels, a clear zero-tolerance policy and an annual review process, we work to protect vulnerable workers and uphold high ethical standards across every part of our commercial waste services in Luton.