Modern Slavery Statement — Commercial Waste Highgate

Commercial Waste Highgate is committed to tackling modern slavery, human trafficking and forced labour across our operations and the supply chain. This Statement explains our approach to preventing exploitation in every aspect of our Highgate commercial waste services and demonstrates our zero-tolerance stance. We publish this declaration to be open and accountable for actions taken and to set clear expectations for partners who provide materials, labour or transport services to Commercial Waste Highgate.

Our commitment is embedded in company policy and day-to-day practice. We operate with zero tolerance for any form of modern slavery in the organisation or among suppliers, contractors and sub-contractors. This includes a prohibition on debt bondage, deceptive recruitment, exploitation of vulnerable workers and withholding of identity documents. The policy applies to all employees, temporary staff and third-party providers involved in commercial-waste Highgate operations.

Risk Assessment and Due Diligence

We maintain a structured due diligence process for procurement and supplier onboarding. Our risk assessment evaluates geographic, sector and service-based indicators to prioritise audits. For higher-risk suppliers we conduct enhanced checks, require contractual anti-slavery clauses and reserve the right to terminate agreements where compliance is not demonstrable. Highgate commercial waste risk mapping informs priority actions and continuous monitoring.

We have implemented practical measures across operations to prevent modern slavery. These include worker identity verification, pay and hours monitoring, and training for operational managers. Our driver welfare checks and vehicle subcontractor vetting are tailored to the waste management sector and reflect the specific operational realities of Commercial-Waste Highgate collection and disposal services. All recruitment must follow transparent, documented procedures.

Supplier Audits and Continuous Monitoring

We conduct regular supplier audits combining document review, on-site assessments and third-party verifications. Audit scopes include employment records, wage payments, recruitment practices and subcontracting arrangements. Findings produce corrective action plans, and persistent non-compliance triggers suspension or termination. Our supplier audit programme targets high-risk categories annually and on an ad-hoc basis following any reportable incident.

To strengthen collaboration, Commercial Waste - Highgate engages suppliers in capacity building and shares best practice through workshops. We require suppliers to commit to our code of conduct and provide evidence of worker protections. Where suppliers operate multi-tiered chains, we seek visibility down the chain and request remediation commitments from our direct contractors for their downstream partners.

We provide multiple, confidential reporting channels so workers and third parties can raise concerns without fear of retaliation. These channels include anonymous reporting hotlines, internal whistleblowing routes and secure written submission options. Reports are treated as urgent, investigated impartially and with appropriate protections for reporters. The reporting framework is widely communicated to staff, drivers and supplier management across all Highgate commercial waste sites.

Our governance and oversight ensure the Statement is implemented consistently. Senior management hold accountability for modern slavery risks and mitigation, with the board receiving annual briefings. We integrate anti-slavery metrics into supplier performance reviews and procurement decision-making. Any confirmed incidents trigger immediate remedial actions, including support for affected individuals and contractual measures against responsible parties.

Annual Review and Continuous Improvement This Statement is reviewed at least once a year to reflect operational changes, evolving risks and lessons learned from audits and reports. We publish updates to improve transparency and ensure that Commercial Waste Highgate remains resilient against modern slavery. The annual review covers policy effectiveness, training uptake, audit outcomes, and incident responses, and sets clear action plans for the following year to strengthen worker protections and supply chain integrity.