Modern Day Slavery Policy
Modern Slavery Policy- Last updated: 08 October 2026
HARDWICK SHERWOOD LTD
Version 1.0 • Policy reference HSL MS 001 • Prepared 2nd October 2026
Policy owner: Directors
Status: Director approval
Effective date: 8th October 2026
Review due: 12 months after approval, or sooner if circumstances change
1 Purpose and commitment
Hardwick Sherwood Ltd is committed to preventing modern slavery and human trafficking in its operations and
supply chains. We will not knowingly participate in, benefit from or tolerate exploitation. This policy sets out
the standards we require, the checks we will undertake and the action to take when concerns arise.
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. Exploitation
can involve threats, violence, deception, debt bondage, withholding wages or identity documents, or
restricting someone’s freedom. It can affect adults and children in the UK and overseas.
2 Scope
This policy applies to directors, employees, casual and temporary workers, agency workers and anyone
working on our behalf. We require suppliers, contractors, subcontractors and labour providers to meet
equivalent standards and communicate them through their own supply chains.
It covers our property and facilities management activities, including commercial facilities management,
communal cleaning, property maintenance, compliance and site checks, electrical equipment testing and
serviced accommodation management. It also covers purchasing, recruitment and work at client premises.
3 Accountability
The directors are responsible for approving this policy, providing proportionate resources, reviewing risks and
overseeing concerns and corrective action. Managers and anyone engaging workers or suppliers must apply
the policy and escalate concerns promptly. All workers must follow the policy, complete relevant awareness
training and report suspected exploitation. Proof is not required before reporting.
4 Fair recruitment and working conditions
We will recruit and engage people fairly, verify identity and right to work as required by law, and explain terms
in a form they can understand. These checks alone do not establish that a person is free from exploitation.
• Work must be freely chosen. People must be able to leave employment subject to lawful contractual
notice, without threats or coercion.
• Workers must receive written terms covering pay, hours and applicable entitlements. Pay must meet
applicable minimum wage requirements; deductions must be lawful, transparent and explained.
• We will not charge workers recruitment fees or permit agencies or intermediaries to charge workers fees
for obtaining work with us. Concerns about fees or recruitment debts must be escalated.
• We will not retain original passports or identity documents, other than temporarily for a lawful check with
consent and prompt return. Workers must control their own documents.
• We will respect lawful working time and rest requirements and provide safe working conditions. We
prohibit threats, violence, intimidation and exploitative child labour.
• Pay should go to an account controlled by the worker. Requests for third-party payment, unexplained
shared accounts or signs that another person controls wages must be checked sensitively before
proceeding.
Before using a labour provider, we will check its identity, recruitment arrangements and employment practices
proportionately. We will check any legally required licence and seek evidence that workers are paid correctly,
receive clear terms and are not charged prohibited fees.
5 Risk assessment and supplier checks
The directors will assess modern slavery risks before engaging higher-risk suppliers or labour providers and
review them at least annually. Relevant risks include labour-intensive cleaning and maintenance, temporary
labour, multiple subcontracting levels, unusually low prices, accommodation linked to employment, and
sourcing uniforms, equipment or materials through unclear supply chains.
Checks will be proportionate to the supplier’s role and risk. They may include verifying business identity,
reviewing policies or statements, asking about labour sourcing and subcontracting, requesting supporting
records, and speaking with workers privately where safe and appropriate. We will record the assessment,
evidence obtained, outstanding concerns and decisions.
For higher-risk arrangements, we will agree clear expectations on fair labour practices, disclosure of
subcontractors, cooperation with checks, prompt reporting of concerns and corrective action. We will
challenge prices or deadlines that could encourage exploitation. A supplier policy or assurance alone is not
sufficient where warning signs remain.
6 Recognising warning signs
Workers may encounter exploitation at client properties, communal areas, accommodation or supplier sites.
Warning signs can include:
• A person appears frightened, is closely controlled, cannot speak freely or is always spoken for by another
person.
• Identity documents, wages, travel or access to a phone are controlled by someone else.
• A person reports threats, recruitment debts, unpaid wages, excessive hours or being unable to leave work
or accommodation.
• Workers appear injured, exhausted or inadequately equipped, or live in overcrowded or unsafe
accommodation linked to work.
• Recruitment arrangements, subcontracting or payment practices are unclear, or a supplier refuses
reasonable questions about labour conditions.
These signs are indicators, not proof. Do not make assumptions based on nationality, appearance or
immigration status. Report the facts you observed and any immediate safety concerns.
7 Reporting a concern
If anyone is in immediate danger, call 999. For non-emergency police reporting, call 101. For specialist advice
or to report suspected exploitation, contact the UK Modern Slavery and Exploitation Helpline on 08000 121
700 or visit www.modernslaveryhelpline.org.
Report concerns promptly to Jonathan Hardwick-Smith, Director, or another director. The company contact
email is info@hardwicksherwood.co.uk. If your concern involves a director, or you do not feel safe using
company channels, contact another director or use the external reporting routes above. Do not delay urgent
external reporting while waiting for an internal response.
Do not confront a suspected exploiter, conduct your own investigation or put yourself or another person at
risk. If it is safe to speak with a potential victim, do so privately and respectfully, listen without pressure and
avoid promises you cannot keep. Use independent interpreting support where needed, rather than someone
who may be controlling them.
Record factual observations, dates, locations and relevant details safely. Share information only with those
who need it to respond. Company email is not an anonymous reporting channel. Anonymous reports may be
made through appropriate external channels.
8 Protection for people raising concerns
No person will suffer retaliation, threats, dismissal or other detrimental treatment for raising an honestly held
concern or assisting with a response, even if the concern is not confirmed. Report suspected retaliation to a
director or through an appropriate external route. We will take it seriously and act promptly.
We will handle reports sensitively and restrict access to personal information. Absolute confidentiality cannot
be guaranteed where information must be shared to protect someone or meet legal obligations.
9 Responding to concerns
A director who is not implicated will oversee the response. Immediate priorities are the safety and welfare of
potentially affected people, appropriate external reporting and avoiding action that increases risk. The
company will seek specialist advice and cooperate with police, safeguarding services and other relevant
authorities.
Where appropriate, we will ask a designated first responder organisation to consider a National Referral
Mechanism referral and explain the support available. The company will not claim to be a designated first
responder or make referrals in that capacity. Consent and safeguarding requirements must be handled with
the relevant professionals.
We will assess the concern promptly, preserve relevant information securely and record decisions and actions.
We will consider safe interim measures, supplier corrective action, lawful recovery of unpaid wages or
recruitment fees, and access to specialist support. We will not penalise a potential victim for being exploited.
Supplier responses may include enhanced checks, a time-bound improvement plan, suspension of new work or
termination in accordance with contract and law. Decisions will take account of the risk to affected workers;
abrupt termination may increase harm. Serious concerns must be reported appropriately even if a contract
ends.
Breaches by employees may result in disciplinary action, up to dismissal, following a fair process. Action
involving other workers or suppliers will reflect their contractual status and applicable law.
10 Awareness records and review
We will provide awareness of this policy during induction and relevant refreshers at least annually. Directors
and people responsible for recruitment, purchasing or site supervision will receive guidance appropriate to
their responsibilities. The policy will be accessible to workers and shared with relevant suppliers.
The directors will review this policy at least annually and following a serious concern, significant operational
change or relevant legal change. The review will consider supplier checks completed, identified risks, training
coverage, reports received, response times and completion of corrective action. An absence of reports will not
be treated as proof that exploitation is absent.
Risk assessments, supplier checks, training and incident records will be held securely with access restricted,
and retained only as long as necessary for their purpose and any applicable legal requirements.
11 Legal context and approval
This policy supports our approach under the Modern Slavery Act 2015. It is an operational policy, not an
annual statement describing completed actions. The directors will assess separately whether the section 54
annual reporting duty applies, including the £36 million total turnover threshold and applicable group turnover
rules, and meet any resulting approval, signature and publication requirements.
Approved on behalf of Hardwick Sherwood Ltd
Director name: Jonathan Hardwick-Smith
Signature: Signature on PDF copy on 1Drive.
Approval date: 8th October 2026
Reference guidance: Modern Slavery Act 2015, section 54 (legislation.gov.uk); Home Office Transparency in Supply Chains guidance
(gov.uk); National Crime Agency modern slavery reporting guidance (nationalcrimeagency.gov.uk). Checked 8 October 2026.
For questions regarding this Modern Day Slavery Policy, the personal information we hold about you or your data protection rights, please contact us:
Hardwick Sherwood Ltd
19 Boulevard
Weston-super-Mare
BS23 1NR