Modern Slavery & Human Trafficking Policy

Revision: 001 | CJB Scaffolding Ltd

1. Purpose

CJB Scaffold Ltd recognises its responsibility to prevent modern slavery and human trafficking within its business operations and supply chains. We are fully committed to ethical business practices, transparency, and compliance with all relevant legislation, including the Modern Slavery Act 2015, the Employment Rights Act 1996, and the Immigration, Asylum and Nationality Act 2006 (Right to Work requirements).

We take a zero-tolerance approach to modern slavery in all its forms and expect the same high standards from our employees, labour suppliers, contractors, and business partners.

This policy sets out the framework by which CJB Scaffold Ltd seeks to identify, prevent, and address risks related to modern slavery and human trafficking.

2. Purpose

The purpose of this policy is to:

Define our approach to identifying, preventing, and responding to modern slavery and human trafficking.
Ensure all employees, suppliers, and partners understand their responsibilities.
Establish clear procedures for recruitment, employment, supply chain management, and reporting.
Demonstrate compliance with the UK Modern Slavery Act 2015 and associated employment laws.

3. Scope

This policy applies to all:

Employees of CJB Scaffold Ltd, including permanent, temporary, and agency workers.
Subcontractors, suppliers, and any third parties working on our behalf.
Activities undertaken at all CJB Scaffold Ltd sites, offices, and project locations.

4. Policy Principles

CJB Scaffold Ltd is committed to:

Ensuring employment is freely chosen and workers are not subject to coercion, forced labour, or bonded labour.
Prohibiting child labour and ensuring no individual under the legal working age is employed.
Upholding fair pay, working hours, and conditions in line with UK labour law.
Conducting transparent and ethical business at every level of our operations.

5. Legal and Regulatory Framework

This policy has been developed in accordance with:

Modern Slavery Act 2015.
Human Rights Act 1998.
Immigration, Asylum and Nationality Act 2006.
Employment Rights Act 1996.
Equality Act 2010.
National Minimum Wage Act 1998.

6. Employment and Recruitment Practices

To prevent modern slavery risks within our workforce, CJB Scaffold Ltd will:

Conduct Right to Work checks on all employees before employment commences, in accordance with UK law.
Verify the authenticity of identification and immigration documents.
Retain records of verification processes for audit purposes.
Ensure that recruitment processes are fair, transparent, and free from discrimination.
Prohibit the charging of recruitment fees or costs to workers by any agency or intermediary.
Ensure all employment terms are provided in writing and explained clearly to each employee.
Maintain regular audits of HR and recruitment practices to identify any areas of risk or non-compliance.

7. Supply Chain Management

CJB Scaffold Ltd recognises that risks of modern slavery may arise in supply chains, particularly where labour-intensive processes are involved. To mitigate this risk, we will:

Conduct due diligence on all new suppliers and subcontractors before engagement.
Require all suppliers to confirm compliance with the Modern Slavery Act 2015.
Include anti-slavery clauses within supplier contracts where applicable.
Request suppliers to provide evidence of their own policies, due diligence procedures, and modern slavery statements.
Monitor and review supplier performance periodically.
Terminate relationships with suppliers or subcontractors found to be in breach of this policy.

8. Training and Awareness

CJB Scaffold Ltd recognises that training and awareness are vital to preventing modern slavery. We will:

Provide induction training to all new employees on ethical conduct, modern slavery awareness, and reporting procedures.
Deliver targeted training to managers, HR personnel, and procurement staff on identifying signs of exploitation or forced labour.
Provide refresher training and awareness materials annually.
Ensure that training records are maintained and reviewed as part of compliance audits.

9. Identifying Signs of Modern Slavery

Employees and contractors should remain vigilant for indicators of modern slavery, including:

Workers showing signs of fear, distress, or reluctance to speak.
Individuals who appear to have limited freedom of movement or communication.
Workers not in possession of their own identification or travel documents.
Discrepancies between actual working conditions and contractual terms.
Evidence of debt bondage or withheld wages.

Any such concerns should be reported immediately using the procedures outlined below.

10. Reporting Concerns

CJB Scaffold Ltd encourages all employees, contractors, and suppliers to report concerns about any issue or suspicion of modern slavery or human trafficking in any part of our business or supply chain.

Reports should be made confidentially to:

Email: HR@cjbscaffolding.co.uk

All reports will be treated seriously, handled sensitively, and investigated promptly.

CJB Scaffold Ltd will ensure that:

No employee or individual will suffer any detriment or retaliation for raising genuine concern.
Appropriate disciplinary or legal action will be taken where violations are confirmed.
Findings and corrective actions are documented and reported to management.

11. Continuous Improvement

We are committed to continuous improvement through:

Annual review of this policy and related procedures.
Regular risk assessments of our operations and supply chains.
Benchmarking against industry standards and legislative changes.
Engaging with suppliers, partners, and stakeholders to enhance awareness and collaboration on ethical practices.

12. Responsibility and Accountability

The Managing Director holds overall responsibility for ensuring compliance with this policy.
The Human Resources Department is responsible for right-to-work checks, training, and managing reported concerns.
All employees are responsible for adhering to this policy and reporting any concerns promptly.