Modern Slavery and Human Trafficking

1. Policy Statement

GWD Services Ltd is committed to preventing slavery and human trafficking in all aspects of its business and supply chains. We have a zero-tolerance approach to modern slavery, and we are fully committed to acting ethically and with integrity in all our business dealings.

2. Purpose

The purpose of this policy is to:
- Set out our responsibilities in observing and upholding our position on modern slavery and human trafficking.
- Provide guidance to employees and supply chain partners on how to identify and prevent such risks.

3. Scope

This policy applies to all persons working for us or on our behalf, including employees, contractors, subcontractors, agency workers, suppliers, and business partners.

4. Responsibilities

- Management is responsible for implementing this policy and ensuring its effectiveness through risk assessments, training, and reporting mechanisms.
- All employees are expected to report any concerns related to modern slavery in any parts of our business or supply chain.

5. Due Diligence in Our Operations and Supply Chain

GWD Services undertake due diligence to identify and mitigate the risk of modern slavery, including:

- Vetting suppliers, subcontractors, and labour providers.
- Requiring all third-party providers to confirm they comply with the Modern Slavery Act 2015.
- Conducting site inspections and labour audits where appropriate.

6. Risk Assessment and Management

We review our operations regularly to assess the risk of modern slavery. The construction sector is considered high-risk due to the use of temporary labour and subcontractors. We work actively to ensure that all individuals working on our behalf are treated fairly and legally.

7. Training and Awareness

We provide training to our staff and key supply chain partners to:
- Recognise signs of modern slavery
- Understand reporting procedures
- Promote a culture of openness and accountability

8. Reporting and Whistleblowing

We encourage anyone who suspects a case of modern slavery to report it confidentially. Reports can be made directly to the Managing Director or via our whistleblowing procedures.

9. Breach of Policy

Any employee found to be involved in modern slavery will face disciplinary action, which may include dismissal. Suppliers and subcontractors found in breach may have their contracts terminated.

10. Review

This policy will be reviewed annually and updated as necessary to ensure compliance with legislation and best practices.