Modern Slavery Policy

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Edwards Commercial Cleaning has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Edwards Commercial Cleaning has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our business

Edwards Commercial Cleaning is a commercial cleaning company operating in the north east of England and Yorkshire. Specialising in the office, factory, medical and educational industries we employ over 400 staff and have around 6 main suppliers.

Our high risk areas

Employing so many staff will always be challenging, especially working in an industry with a relatively high turnover of staff. We ensure that from the initial application through to interview and start up, checks are in place to mitigate the risk of employing people who may be in forced labour. We ensure that they are contactable (mobile or landlines) and have an address. The checks include referencing previous employers, ensuring the individual has a bank account in their name and a National Insurance number and where we think the applicant is not a British national, checking passport / permit to work papers and keeping records. Our payroll system is linked to HMRC and tax codes then being provided is a sign that an individual is genuine.

Our policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. This Anti-slavery policy.  This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help. 
2. Recruitment policy. We operate a robust recruitment policy as mentioned above, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. 
3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Codes of business conduct (Sales and Operations Manuals which are part of our ISO9001 quality system).  This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

Our suppliers

Edwards Commercial Cleaning operates a supplier policy and maintains a preferred supplier list.  We conduct due diligence on all suppliers before allowing them to become a preferred supplier.  This due diligence includes an online search to ensure that particular organisation has never been convicted of offences relating to modern slavery.  Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. 

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that: 

1. They have taken steps to eradicate modern slavery within their business.
2. They hold their own suppliers to account over modern slavery.
3. They pay their employees at least the national minimum wage / national living wage (as appropriate)
4. We may terminate the contract at any time should any instances of modern slavery come to light.

Reviews

We regularly conduct reviews for our employment and purchasing teams (Operations and Administration) so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified anywhere within the business or in our supply chain.

Approval for this statement

This statement was approved and reviewed by the Directors on 15th November 2025

Name:  Paul Edwards
Date: 15th November 2025