1: Introduction

1.1 Policy Overview
United Civils Limited recognises that modern slavery is a serious violation of human rights and a criminal offence. This Policy outlines our commitment to preventing slavery, servitude, forced labour, and human trafficking within our organisation and supply chain.

1.2 Statement of Commitment
United Civils Limited has zero tolerance for modern slavery. We are committed to acting ethically, with integrity and transparency in all business dealings, and to ensuring our labour practices—and those of our supply chain—are free from modern slavery.

2: Purpose

2.1 Objectives of the Policy
The aims of this Policy are to:

2.1.1 Comply with the requirements of the Modern Slavery Act 2015.
2.1.2 Prevent the use of forced or trafficked labour within our workforce or subcontractors.
2.1.3 Ensure due diligence in our supply chain to identify and reduce modern slavery risks.
2.1.4 Promote awareness among staff, subcontractors, and suppliers.

3: Scope

3.1 Applicability
This Policy applies to:

• All employees of United Civils Limited.

• Subcontractors, agency staff, and labour providers.

• Suppliers, service providers, and third parties engaged by the company.

3.2 Definitions
Modern slavery includes:

• Forced labour – where a person is forced to work against their will.

• Human trafficking – where individuals are moved or recruited through coercion for exploitation.

• Debt bondage – where individuals work to repay debts they cannot realistically clear.

• Child labour – where children are exploited in a way that is mentally, physically, or morally harmful.

4: Responsibilities

4.1 Managing Director – Scott Bland

4.1.1 Has overall responsibility for ensuring the company’s compliance with this Policy.
4.1.2 Oversees any investigations or corrective action related to modern slavery risks.

4.2 HSEQ Consultants – SEHSS Limited

4.2.1 Provides training and advice on compliance with this Policy.
4.2.2 Supports supplier screening and risk monitoring.
4.2.3 Investigates reports of suspected modern slavery and maintains appropriate records.

4.3 Supervisors and Site Managers

4.3.1 Must remain alert for warning signs of forced labour on site.
4.3.2 Are responsible for reporting concerns without delay.

4.4 Employees and Contractors

4.4.1 Must not engage in any activity that supports modern slavery.
4.4.2 Must report any concerns immediately to a manager, Scott Bland.

5: Labour Standards and Ethical Employment

5.1 Working Conditions

5.1.1 All employees and subcontractors must work voluntarily and have the legal right to work in the UK.
5.1.2 All individuals must be free to leave their employment with appropriate notice.

5.2 Wages and Benefits

5.2.1 All workers must be paid at least the National Minimum Wage.
5.2.2 No unlawful deductions, fees, or withheld wages are permitted.
5.2.3 Workers must have access to payslips detailing hours worked and pay received.

5.3 Identification and Documentation

5.3.1 No one will be required to surrender original identity documents as a condition of employment.
5.3.2 Right to work checks will be conducted in line with UK Home Office requirements.

6: Supply Chain Expectations

6.1 Subcontractors and Labour Providers

6.1.1 Must confirm that their operations and labour practices are free from modern slavery.
6.1.2 Must provide assurance that they undertake right-to-work checks and fair wage practices.

6.2 Risk-Based Due Diligence

6.2.1 Where high-risk suppliers or subcontractors are engaged, additional checks may be required.
6.2.2 United Civils Limited reserves the right to audit suppliers or request supporting evidence.

6.3 Contractual Controls

6.3.1 Contracts will contain clauses requiring compliance with the Modern Slavery Act 2015.
6.3.2 Non-compliance may result in termination of agreements and reporting to authorities.

7: Reporting and Whistleblowing

7.1 Reporting Concerns

7.1.1 All employees and subcontractors are encouraged to report concerns or suspicions of modern slavery.
7.1.2 Reports can be made to a line manager, Scott Bland in confidence.

7.2 Whistleblower Protection

7.2.1 Reports will be treated seriously and confidentially.
7.2.2 There will be no victimisation or retaliation for reporting concerns in good faith.

7.3 Response to Allegations

7.3.1 Any allegation of modern slavery will be investigated promptly.
7.3.2 If confirmed, United Civils Limited will take appropriate disciplinary and legal action, and notify the authorities.

8: Training and Awareness

8.1 All staff will receive awareness training as part of their induction.
8.2 Toolbox talks and refresher briefings may be used to reinforce understanding.
8.3 Posters or brief guidance may be displayed on sites to promote awareness of red flags and reporting channels.

9: Policy Review

9.1 This Policy will be reviewed annually or in response to any incident, legislation change, or industry update.
9.2 The review will be conducted by SEHSS Limited and approved by Scott Bland.
9.3 Any changes will be communicated to employees, subcontractors, and relevant suppliers.

10: Legal and Regulatory Considerations

10.1 This Policy complies with the requirements of the Modern Slavery Act 2015.
10.2 United Civils Limited supports the UK Government’s objectives to eradicate slavery and human trafficking.
10.3 We will maintain awareness of evolving legislation, guidance, and industry best practices in this area.