Modern Slavery Statement — Commercial Waste Leatherhead

This Modern Slavery Statement sets out the commitment of Commercial Waste Leatherhead and affiliated operations to prevent modern slavery and human trafficking across our supply chains and services. We recognise the ethical and legal obligations that accompany waste management and recycling operations in Leatherhead, and we are dedicated to ensuring labour standards are upheld in every part of our business and in the activities of our contractors and suppliers.

Our policy is a zero-tolerance policy towards modern slavery. Commercial waste in Leatherhead must never be associated with forced labour, debt bondage or exploitative practices. We require all colleagues, contractors and partners to adhere to this principle and to report any concerns through the channels described below. The statement applies to all divisions delivering Leatherhead commercial waste services, including collection, transportation and disposal arrangements.

We maintain clear governance for anti-slavery measures. Senior management is accountable for ensuring policies are implemented, and board-level oversight is provided to review risks and controls for Leatherhead commercial waste operations. We publish this statement annually and communicate expectations to our workforce and supply chain, emphasising that compliance with anti-slavery standards is a condition of doing business with us.

To minimise risk across our value chain, we operate a structured supplier audit and due diligence programme. Supplier audits examine recruitment practices, working hours, pay, identity verification and freedom of movement for employees working on contracts associated with Commercial Waste Leatherhead. Audits are undertaken by our compliance team and, where appropriate, by independent third parties.

Our procurement and supplier management processes include pre-qualification checks, contractual clauses prohibiting modern slavery, and periodic on-site inspections. We use a risk-based approach to prioritise suppliers for deeper review, focusing on labour-intensive activities, subcontracting layers and high-risk geographies linked to the Leatherhead commercial waste sector.

Key elements of our supplier assurance programme include:

• Documented due diligence before onboarding suppliers, including identity and reference verification;
• Periodic audits and site visits to verify working conditions and pay practices;
• Mandatory contractual clauses that require suppliers to comply with anti-slavery laws and allow us to terminate agreements for breaches;
• Training for procurement staff and contract managers to recognise signs of forced labour and exploitation.

Reporting channels are available to all employees, contractors and third parties. We encourage anyone with concerns about modern slavery within Commercial Waste Leatherhead to report them promptly via internal whistleblowing channels or anonymous third-party reporting mechanisms. Reports are treated seriously, investigated promptly and independently, and appropriate remedial action will be taken where issues are identified.

We protect reporters from retaliation and offer confidential and anonymous reporting options. Leatherhead commercial waste staff receive training on how to raise concerns and managers are trained to respond effectively. Our investigation process aims to establish facts quickly, protect vulnerable individuals and, where necessary, engage relevant law enforcement or labour authorities.

We commit to continuous improvement and annual review of our policies and processes. Each year, the effectiveness of our anti-slavery actions is reviewed by senior leadership; outcomes are used to refine risk assessments, supplier audit frequency and training programmes. This annual review ensures that our approach to preventing slavery within the Commercial Waste — Leatherhead operations remains robust and responsive to emerging risks.