Commercial Waste Harrow Modern Slavery Statement

Commercial Waste Harrow is committed to eradicating modern slavery and human trafficking from its operations and supply chain. This statement sets out our zero-tolerance policy and the steps we take to identify, prevent and respond to risks of exploitation. As a Harrow commercial waste provider, we recognise our responsibility to uphold labour rights and to ensure that all workers linked to our services are treated with dignity and fairness.

We operate a clear zero-tolerance stance: any evidence of forced labour, debt bondage, child labour or human trafficking will trigger immediate action, including contract termination and cooperation with relevant authorities. Our Commercial Waste — Harrow teams receive training to spot indicators of modern slavery and to escalate concerns through formal reporting channels described below.

Our approach to due diligence focuses on high-risk areas in operations and subcontracting. We map the Harrow commercial waste supply chain, identify critical suppliers and service routes, and apply proportionate checks. These checks include worker verification, review of recruitment practices, and assessment of accommodation where provided by subcontractors or partners. We prioritise transparency and continuous improvement in all procurement activities.

Supplier Audits and Monitoring

Supplier audits form a core part of our compliance programme. We conduct routine and spot audits of key suppliers, integrating both desk-based reviews and on-site inspections where feasible. Audit activities examine payroll records, working hours, safety standards and recruitment fees. Where risks are identified, we require corrective action plans and follow-up verification. Our Harrow commercial waste contractors are contractually obliged to comply with our modern slavery terms and provide evidence on request.

We maintain a risk-based audit schedule that increases scrutiny for suppliers operating in higher risk sectors or geographies. Audit outcomes are reported to senior management and used to inform procurement decisions. We also encourage suppliers to adopt similar anti-slavery measures and to include protections for agency and temporary staff in their policies.

Our procurement team uses a combination of internal checks and third-party assessments to validate supplier declarations. When audit findings reveal non-compliance, we implement remediation steps which may include targeted training, contractual penalties or transition to alternative suppliers.

Reporting Channels and Whistleblowing

We provide secure and confidential reporting channels for workers, suppliers and the public to raise concerns about modern slavery. Reports are assessed promptly, with appropriate investigation and protective measures for potential victims. All allegations are treated seriously and investigated by trained staff to ensure safe outcomes. The Harrow commercial waste services teams coordinate internal responses and ensure issues are escalated to senior leadership.

To support transparency, our reporting framework includes:

• Anonymous reporting mechanisms for whistleblowers
• Formal incident logs and investigation protocols
• Clear escalation procedures to senior management

Annual Review and Continuous Improvement: We review this statement and our anti-slavery measures at least once every 12 months. The annual review assesses policy effectiveness, audit findings, training coverage and reported incidents. Outcomes of the review drive updates to our risk assessments, supplier due diligence and staff training. We are committed to evolving our practices to reflect emerging risks and best practice in the waste sector.