Modern slavery and human trafficking policy

1. Policy Statement

Aspect Maintenance Services Limited (“the Company”) is committed to preventing modern slavery and human trafficking in all its business activities and supply chains. The Company operates with integrity and transparency and adopts a zero-tolerance approach to any form of modern slavery.

This policy is in accordance with the Modern Slavery Act 2015 and reflects our commitment to ethical business practices and the protection of human rights.

2. Scope

This policy applies to:

  • All employees at all levels
  • Directors and officers
  • Contractors, subcontractors, and agency workers
  • Suppliers and business partners

It applies to all operations and supply chains associated with the Company.

3. Definition of Modern Slavery

Modern slavery is a crime and a violation of fundamental human rights. It includes:

  • Slavery and servitude
  • Forced or compulsory labour
  • Human trafficking
  • Debt bondage
  • Exploitative child labour

These practices involve the exploitation of individuals for personal or commercial gain.

4. Our Commitment

The Company is committed to:

  • Ensuring there is no modern slavery or human trafficking within our business or supply chains
  • Acting ethically and with integrity in all business relationships
  • Implementing and enforcing effective systems and controls to mitigate risks
  • Promoting transparency across operations

5. Responsibilities

Management

  • Ensure compliance with this policy
  • Conduct risk assessments across operations and supply chains
  • Implement due diligence procedures

Employees

  • Must comply with this policy
  • Must remain vigilant to signs of modern slavery
  • Must report any concerns immediately

6. Risk Assessment

The Company recognises that modern slavery risks may arise in:

  • Subcontracting arrangements
  • Supply chains (particularly labour-intensive services)
  • Temporary or agency labour

To address this, the Company will:

  • Assess risk levels in its operations and supply chains
  • Prioritise higher-risk areas for further scrutiny
  • Review practices regularly

7. Due Diligence

The Company will:

  • Carry out due diligence on suppliers and subcontractors
  • Require suppliers to confirm compliance with anti-slavery laws
  • Include anti-slavery provisions in contracts where appropriate
  • Terminate relationships with organisations found to be in breach

8. Indicators of Modern Slavery

Employees should be alert to warning signs, including:

  • Individuals appearing fearful, withdrawn, or under the control of others
  • Lack of personal documentation or restricted movement
  • Poor working conditions or excessive working hours
  • Unusual payment arrangements (e.g., wages withheld or paid to third parties)

9. Reporting Concerns

Any concerns regarding modern slavery or human trafficking must be reported immediately to:

  • Senior management
  • The Company director

All concerns will be treated confidentially, and individuals will not suffer retaliation for reporting genuine concerns.

10. Training and Awareness

The Company will:

  • Provide appropriate training to employees on identifying and preventing modern slavery
  • Ensure relevant staff understand risk areas and reporting procedures

11. Monitoring and Review

The Company will:

  • Regularly review and update this policy
  • Monitor its effectiveness and take corrective action where necessary

12. Breach of Policy

Any breach of this policy may result in:

  • Disciplinary action, including dismissal
  • Termination of contracts with suppliers or partners
  • Legal action, where applicable

13. Approval and Sign-Off

This policy is approved by senior management and is effective from the date of signature below.

Mr Will Davies- CEO

1st April 2026

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