Modern Slavery & Human Trafficking Policy

1. Policy Statement. Scott’s Tree Surgery and Garden Maintenance Ltd is committed to maintaining the highest standards of ethical conduct and corporate responsibility. We have zero tolerance for modern slavery, human trafficking, forced labour, debt bondage, labour exploitation and child labour within our business operations or supply chains. We are committed to acting ethically and with integrity in all business relationships and to implementing effective systems, controls and due diligence.
   
   
2. Business Activities & Operational Context Scott’s Tree Surgery and Garden Maintenance Ltd provides:

• • Tree surgery & arboricultural services (including emergency works).
  • Gardening, grounds and estate management.
  • Site clearance.
  • Green waste handling, haulage and recycling.
  • Domestic, commercial and local authority contracts.

Our supply chain includes subcontract climbers and grounds operatives, agency labour, PPE and clothing supply, machinery and plant, fuel and lubricants, green waste processing, timber/biomass outlets, and horticultural supply chains.

3. Legislative Framework. This Policy supports compliance with the:

• • Modern Slavery Act 2015 (UK)
  • Human Rights Act 1998
  • Employment Rights Act 1996
  • Equality Act 2010
  • Working Time Regulations 1998
  • National Minimum Wage / National Living Wage Regulations
  • Health & Safety at Work etc. Act 1974
  • ILO Forced Labour Conventions

Where external clients impose stricter standards (e.g., utilities or public sector frameworks), Scott’s Tree Surgery and Garden Maintenance Ltd will align with those additional requirements.

4. Risk Assessment. Modern slavery risks within our sector may arise in:

• • Labour-only subcontracting
  • Agency/seasonal labour recruitment
  • PPE and clothing supply chains (global sourcing)
  • Timber, biomass and horticultural materials
  • Machinery, plant and fuel chains
  • Waste and recycling streams
  • Logistics and transportation

Risk levels may change depending on contract type, geography, supply route and seasonal demand.

5. Organisational Governance Responsibility for this Policy sits with Senior Management, who ensure:

• • Policy implementation and oversight
  • Approval of supplier/contract controls
  • Monitoring and assurance activity
  • Reporting to clients and stakeholders when requested

Operational managers are responsible for risk recognition, site controls, subcontract oversight and reporting concerns.

6. Due Diligence Procedures. We conduct proportionate due diligence on:

• • Subcontractors
  • Labour agencies
  • Material suppliers
  • Waste/recycling partners
  • Fuel and plant suppliers

Due diligence may include: – Supplier declarations & contractual terms – Right-to-work verification (where labour is supplied) – Ethical sourcing screening – Periodic audits or site visits (where proportionate) – Certification checks (e.g., SSIP, ISO)

7. Employment & Recruitment Practices. We maintain robust controls to ensure:

• • All workers have a legal right to work in the UK
  • Wages are paid directly to the worker
  • No worker pays recruitment fees
  • No passports/ID are retained by the company or subcontractors
  • Contracts clearly describe terms of employment
  • Working hours are voluntary and compliant with legislation

We do not engage forced, bonded or uncompensated labour.

8. Subcontractor & Supplier Requirements. Subcontractors and suppliers must:

• • Confirm compliance with the Modern Slavery Act 2015
  • Demonstrate ethical labour practices upon request
  • Implement right-to-work checks for their labour
  • Agree not to subcontract labour without approval
  • Notify Scott’s Tree Surgery and Garden Maintenance Ltd of any modern slavery concerns

We reserve the right to terminate agreements with suppliers who fail to comply.

9. Training & Awareness. Relevant personnel (e.g., HR, procurement, contract managers, site managers) receive training or briefing to understand:

• • Indicators of slavery and exploitation
  • Risks in subcontract labour chains
  • Reporting routes and whistleblowing
  • Ethical procurement principles

Training delivery may be internal, external or via e-learning depending on contract requirements.

10. Whistleblowing & Reporting Mechanisms. Concerns can be raised confidentially through internal reporting channels or externally. We support open escalation without fear of retaliation. Where appropriate, we may notify:

• • Law enforcement
  • Local authorities
  • The Modern Slavery Helpline (08000 121 700)
    
    

11. Monitoring & Continuous Improvement. We will:

• • Review due diligence at least annually
  • Strengthen procurement and subcontract controls
  • Update training and induction content
  • Engage with public sector and industry guidance
  • Support transparency and ethical supply chain practices
    
    

12. Review & Approval. This Policy is reviewed annually, or sooner if:

• • Legislation changes
  • Client requirements change
  • Due diligence identifies new risks
    
    
    

Signed: Name: ___________________________

Position: _________________________________          Date: ____________________________