Modern Slavery Statement — Commercial Waste Sudbury

Commercial Waste Sudbury is committed to preventing modern slavery and human trafficking in all forms across our operations and supply chain. This statement sets out the steps taken by Commercial Waste Sudbury and related Sudbury commercial waste services to identify, assess and mitigate the risk of modern slavery. We recognise our responsibility to maintain a workplace where the rights and dignity of workers are respected, and we adopt a zero-tolerance approach to slavery and forced labour.

Our zero-tolerance policy is clear: any form of modern slavery, servitude, forced or compulsory labour, or human trafficking is unacceptable. All employees, contractors and suppliers of Commercial Waste - Sudbury must comply with this policy. We require every colleague and partner to act with integrity and to report concerns. The policy is reinforced through mandatory training, clear contractual obligations, and visible leadership commitment.

We expect suppliers and partners in the Sudbury waste collection sector to adhere to our standards. Supplier selection and ongoing engagement involve due diligence checks and contract clauses that require compliance with anti-slavery legislation. Where risk indicators are identified, we undertake proportionate supplier audits and site visits to ensure labour practices meet our standards and to verify employment records, working conditions and payment practices.

The Board and senior management of Commercial Waste Sudbury approve and publish this statement annually. We embed our commitments into procurement processes for the wider Sudbury commercial waste network and ensure that senior leaders take ownership of risk assessments. Staff training emphasises how to recognise signs of exploitation and the importance of immediate escalation.

Our approach to supplier audits is risk-based: we prioritise higher-risk suppliers and subcontractors, especially where labour is sourced through agencies or where low-skilled manual work is required. Audit activities include document reviews, worker interviews and third-party verification. If non-compliance is found, we require corrective action plans and may suspend or terminate relationships where issues are not remediated promptly.

We use a range of preventative measures including pre-engagement screening, contractual clauses requiring compliance with anti-slavery standards, and ongoing monitoring of suppliers. Commercial waste sudbury operations are periodically reviewed to assess whether our processes effectively reduce the risk of modern slavery in operational activities such as collection, transfer, and disposal.

Reporting channels are in place to enable staff, contractors and third parties to raise concerns about suspected modern slavery in a safe and confidential manner. We encourage reports through internal escalation routes, direct reporting to compliance teams, and anonymous reporting mechanisms. All reports are taken seriously, investigated by trained personnel, and acted upon in line with our response procedures.

To support grievance handling and remediation, our procedures set out steps to protect vulnerable workers and provide access to appropriate support services where needed. The Sudbury commercial waste services group ensures that any remediation is victim-centred and that those affected are treated with respect and dignity. Whistleblowers are protected from retaliation in accordance with our policies.

Annual review and continuous improvement are central to how we manage modern slavery risk. Each year we review policy effectiveness, audit outcomes, supplier performance and incident responses. This Modern Slavery Statement is reviewed and updated at least once per year by senior management to reflect changes to legislation, emerging risks in the waste management sector, and lessons learned from audits and reports. We will continue to strengthen oversight of our supply chain and to work with partners across the industry to eradicate modern slavery from all aspects of our operations.