Modern Slavery Statement for Toms Waste

Toms Waste is committed to a robust Modern Slavery Statement that reflects our commitment to prevent exploitation across our operations and supply chain. This anti-slavery declaration sets out our zero-tolerance approach to forced labour, human trafficking and other forms of modern slavery. We publish this modern slavery policy to be transparent about the steps we take to identify, mitigate and remediate risks.

We operate with a clear zero-tolerance policy on slavery and human trafficking. Our expectation is that every employee, contractor and supplier adheres to our standards. The company’s governance requires senior management endorsement of the anti-slavery statement and accountability for its implementation across every business unit.

Scope and Risk Assessment

Toms Waste conducts regular risk assessments of our operations and purchasing categories to identify where slavery and exploitation are most likely to occur. The slavery and human trafficking statement covers direct employees, contracted services, logistics providers and material suppliers. We use a risk-based approach and update our assessment annually to reflect changing supply chain dynamics and geographical risks.

Our procurement process integrates supplier due diligence: supplier pre-qualification, contract clauses embedding our modern slavery policy, and mandatory ethical requirements. We include an explicit Supplier Code of Conduct in supplier agreements and require evidence of compliance with labour standards before engaging new partners.

Supplier Audits and Monitoring

Supplier audits are a core control. We conduct scheduled and unannounced audits, combining desktop reviews, on-site inspections and worker interviews where permitted. Non-conformances trigger corrective action plans; serious breaches lead to termination of contracts. Audit findings are reported to the compliance committee and used to inform supplier development and remediation plans.

To strengthen prevention, we run risk-based supplier monitoring that includes:

• document reviews of payroll and working hours
• verification of recruitment practices to prevent debt bondage
• inspection of working and living conditions where relevant

These measures support our objective to eradicate forced labour in all tiers of our supply chain.

We maintain multiple confidential reporting channels to enable workers and stakeholders to raise concerns without fear of retaliation. These reporting mechanisms include protected internal reporting lines and anonymous reporting options. All reports are investigated promptly, impartially and with sensitivity to the reporter’s confidentiality and safety.

Toms Waste provides training for employees and key suppliers to raise awareness of modern slavery indicators and appropriate responses. Training focuses on frontline staff and procurement teams, equipping them to spot risks and escalate concerns. We also support suppliers in implementing corrective actions and developing sustainable labour practices.

Remediation and continuous improvement are integral to our response. When instances of exploitation are identified, we prioritize the welfare of affected individuals, work with third parties and local authorities when necessary, and apply proportional remedies. We treat remediation as an opportunity to strengthen systems and prevent recurrence.

Governance of the anti-slavery statement is overseen by the Executive Compliance Lead and reported to the Board. We maintain clear roles and responsibilities for policy implementation, risk management and supplier engagement. Strong oversight ensures that our modern slavery statement remains embedded across business processes and decision-making.

We commit to transparency and continual improvement. Our modern slavery reporting includes performance indicators such as number of audits conducted, supplier compliance rates and remedial actions completed. These metrics inform management decisions and resource allocation to high-risk areas.

Annual review: This modern slavery statement is reviewed at least once a year to assess effectiveness and to update our risk profile, policies and procedures. The review process includes consultation with internal stakeholders and input from third-party experts where appropriate. Following each review, we publish an updated statement detailing progress, findings and planned actions to strengthen our response to modern slavery and human trafficking.