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Modern Slavery Policy

Effective Date: 01.10.2025
Review Date: 01.10.2026

1. Policy Statement
New Beginnings Bristol Limited is committed to acting ethically and with integrity in all our business dealings and relationships. We have zero tolerance for any form of modern slavery, human trafficking, forced labour or exploitation (“modern slavery”). We expect the same high standards from all persons working for us and with us including employees, contractors, suppliers and business partners.

2. Scope
This policy applies to all staff (permanent, fixed-term, temporary), contractors, volunteers, subcontractors and business partners. It covers all of our operations in the UK, and our supply chain, insofar as we can influence it.

3. Definitions
For the purposes of this policy:

  • “Modern slavery” includes slavery, servitude, forced or compulsory labour, human trafficking, and other exploitation of individuals for personal or commercial gain. Parliament News+1
  • “Supply chain” describes the network of suppliers, subcontractors and business partners who contribute to the provision of our services or procurement of goods.

4. Our Responsibilities
We will:

  • Seek to identify and assess potential risk areas in our business and supply chains.
  • Undertake appropriate due diligence in relation to our procurement and supply relationships (for example, checking that suppliers share our values and do not tolerate modern slavery).
  • Ensure our terms and conditions and supplier agreements incorporate obligations respecting the prohibition of modern slavery.
  • Provide training and awareness for staff so that they understand the risks of modern slavery, can recognise the signs and know how to report concerns.
  • Provide a confidential mechanism for reporting suspected modern slavery, without fear of retaliation.
  • Review this policy and our practices on at least an annual basis.

5. Risk Assessment and Supply Chains
We recognise that certain sectors and geographies carry higher risk of modern slavery. We will:

  • Map key aspects of our supply chain (goods/services, geographic origin, labour practices) so far as practical.
  • Prioritise higher-risk suppliers, subcontractors or those operating in high-risk countries or sectors for closer scrutiny.
  • Require our suppliers and contractors to confirm that they comply with all applicable employment, labour and human rights laws and that they take steps to prevent modern slavery.
  • Terminate relationships if a supplier is found to be in breach of our policy and fails to take remedial action.

6. Training and Awareness
We will provide training and awareness-raising so that our employees and relevant contractors understand:

  • What modern slavery is and the forms it may take.
  • How it might manifest in our business or supply chains (for example excessive working hours, non-payment of wages, debt bondage, restrictions on movement).
  • How to report concerns and escalate issues.
  • How our procurement and supplier assessment processes help mitigate risk.
    We will review training periodically and ensure new joiners and those with procurement/supplier responsibilities receive the training.

7. Reporting Concerns and Whistle-blowing
If anyone working with or for us becomes aware of or suspects modern slavery:

  • They should report their concerns immediately to [insert designated person or department] or via [insert anonymous/whistle-blowing mechanism if available].
  • We will act promptly, investigating the matter, supporting any victims, and taking appropriate remedial action (including termination of supplier relationship, referral to authorities if required).
  • We will protect whistle-blowers from retaliation.

8. Monitoring and Review
We will monitor our effectiveness in implementing this policy. This will include:

  • Keeping internal records of supplier audits / assessments, training completion, incident reports and corrective actions taken.
  • Reviewing and updating this policy at least annually or when significant changes occur in our business or supply chains.
  • Reporting to senior management on compliance, risk areas and progress.

9. Governance & Approval
This policy is approved by the board/directors of New Beginnings Bristol Limited and is owned by [insert job title, e.g., “Operations Director” or “Compliance Manager”]. Responsibility for implementation lies with the senior management team and all staff have a role to play in enforcing it.

10. Communication
This policy will be communicated to all employees, contractors and business partners on induction and will be available on our website and/or internal intranet. We will ask suppliers to acknowledge this policy and commit to comply with it or provide equivalent assurances.

11. Related Policies
This policy should be read in conjunction with our:

  • Code of Conduct / Ethics Policy
  • Whistle-blowing Policy
  • Procurement Policy
  • Human Resources / Employment Policy

Signature:

Name: Sharon Davis
Title: Director
Date: 01.10.2025