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Modern Slavery Statement

Modern Slavery Statement Policy

1) Purpose and scope

ecosense is committed to conducting business ethically and with integrity, and to ensuring modern slavery and human trafficking are not taking place in any part of our business or supply chains. This policy applies to all employees, workers, agency staff, contractors, consultants, suppliers, and any other third parties acting on our behalf in the UK and overseas.

This policy supports our obligations under the Modern Slavery Act 2015 and aligns with internationally recognised standards, including the ILO Fundamental Conventions and the UN Guiding Principles on Business and Human Rights.

 

2) Our business and supply chains

ecosense provides nationwide contract cleaning and related services across multiple sectors. Our supply chains include (but are not limited to): facilities services subcontractors, temporary labour providers, equipment manufacturers, uniform and PPE suppliers, chemical and consumables suppliers, waste and recycling providers, and logistics.

 

3) Zero-tolerance statement

We have zero tolerance for slavery, servitude, forced or compulsory labour, debt bondage, child labour that is exploitative or unlawful, and human trafficking. We expect the same high standards from all who work with us. Breaches of this policy may result in termination of employment or contract and, where appropriate, reporting to the authorities.

 

4) Governance and responsibilities

  • Board of Directors: overall accountability; approves annual statement and KPIs.

  • Managing Director: executive owner of the policy and its implementation.

  • Head of People / HR: due diligence on recruitment and agency labour; training; grievance and whistleblowing.

  • Procurement / Supply Chain: supplier screening, contracting standards, audits, and remediation.

  • Operational Managers & Contract Managers: day-to-day compliance, worker engagement, site spot-checks.

  • All workers: duty to report concerns and comply with this policy.

 

5) Risk assessment

We conduct a risk-based assessment at least annually (and when onboarding new categories of suppliers), focusing on:

  • Use of temporary/agency labour and subcontracting.

  • Sectors and geographies with elevated risk (e.g., uniforms/PPE manufacturing, logistics).

  • Indicators such as recruitment fee charging, document retention, excessive overtime, tied accommodation, or wage deductions.

Outcomes inform our priorities for due diligence, audits, and training.

 

6) Due diligence and supplier standards

We apply proportionate controls across the lifecycle of supplier and labour engagement:

6.1 Onboarding

  • Supplier pre-qualification including modern slavery questionnaire and sanctions screening.

  • Acceptance of ecosense Supplier Code of Conduct (or equivalent standards), covering: freely chosen employment; no recruitment fees; right-to-work; fair wages; working hours; freedom of movement and association; safe working conditions; and grievance access.

  • Contract clauses requiring compliance with the Modern Slavery Act 2015, audit cooperation, incident notification within 48 hours, and remediation obligations.

6.2 Recruitment and employment

  • Right-to-work checks conducted directly by ecosense or audited agencies; no retention of passports or personal documents.

  • Strict prohibition of worker-paid recruitment fees; use of reputable, licensed labour providers (including GLAA-licensed where applicable).

  • Clear written terms of employment in a language understood by the worker.

  • Payroll paid directly to workers’ own bank accounts where feasible; monitoring for red flags (multiple workers paid to the same account, unusual deductions).

6.3 Monitoring and audits

  • Risk-based audits (desk and on-site), worker interviews, and spot-checks at sites.

  • Corrective Action Plans with time-bound remediation; escalation to suspension or termination for non-compliance.

 

7) Training and awareness

  • Induction training for all employees on recognising and reporting modern slavery indicators.

  • Annual refresher training for managers, HR, procurement, and site supervisors.

  • Supplier briefings where risk is higher (e.g., labour providers, garment manufacturers).

Key warning signs covered include: restricted movement, debt bondage, excessive overtime, crowded or tied accommodation, fear of authorities, withholding of documents, and wage withholding.

 

8) Reporting concerns (speak-up)

We encourage early reporting in good faith. Reports can be made confidentially via:

  • Line manager or HR (in person or email: [HR email])

  • Whistleblowing channel: [hotline/email if available]

  • Modern Slavery & Exploitation Helpline (UK): 08000 121 700

  • Police: 999 (emergency) or 101 (non-emergency)

No reporter will suffer retaliation for raising concerns in good faith. Anonymous reports will be considered, though investigation may be limited.

 

9) Response, remediation, and victim support

When concerns are raised, we will:

  1. Act immediately to protect individuals and manage risk on site.

  2. Investigate promptly and sensitively, involving competent personnel and, where appropriate, the Police, the GLAA, local safeguarding teams, or the UK National Referral Mechanism (NRM).

  3. Remediate adverse impacts, prioritising the safety and welfare of affected workers (e.g., access to pay, safe accommodation, support services).

  4. Correct root causes with suppliers; if remediation fails or bad faith is evident, we will suspend or terminate the relationship.

Records of investigations and outcomes are retained in line with our data protection policies.

 

10) KPIs and performance measurement

We track and report (internally, and externally where required) on:

  • % of higher-risk suppliers assessed/contracted with anti-slavery clauses.

  • % of relevant employees and managers trained.

  • Number and nature of concerns raised and closed; remediation outcomes.

  • Audit findings and Corrective Action Plan closure rates.

  • Right-to-work and payroll anomaly checks completed.

 

11) Communication and transparency (Section 54 statement)

Where ecosense (L Burridge Ltd) meets the statutory threshold under Modern Slavery Act 2015 s.54 (currently £36m global turnover), we will publish an annual slavery and human trafficking statement approved by the Board and signed by a Director, detailing steps taken in the previous financial year.
If below the threshold, we will voluntarily publish a concise statement reflecting our commitment and progress.

 

12) Related policies and documents

  • Supplier Code of Conduct

  • Procurement & Ethical Sourcing Policy

  • Recruitment & Agency Worker Policy

  • Whistleblowing (Speak-Up) Policy

  • Grievance Policy

  • Health, Safety & Wellbeing Policy

  • Data Protection Policy

 

13) Review and ownership

This policy will be reviewed at least annually by the Board (or sooner following legislative changes, incidents, audits, or risk reassessments). Updates will be communicated to all employees and relevant suppliers.

 


Matthew Burridge, Director
For and on behalf of L Burridge Ltd t/a ecosense

 

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