Chartwell Design and Build Limited

Anti-Slavery and Human Trafficking Policy

 

Policy owners: Aaron Humber and Mark Hillman (Directors)

Date approved: 21 August 2026

Next review date: 21 August 2027

Applies to: All staff, subcontractors, agency workers, suppliers and consultants working for Chartwell Design and Build Limited

  1. Our commitment

Chartwell Design and Build Limited has a zero-tolerance approach to modern slavery and human trafficking. This means we will never knowingly use forced, bonded or trafficked labour, and we expect the same standard from everyone we work with. This policy applies to our own business and to our whole supply chain, including subcontractors, trade contractors, recruitment agencies, suppliers and consultants.

This policy follows the Modern Slavery Act 2015. We are committed to acting responsibly whether or not the company is legally required to publish an annual statement under the Act.

  1. Why this matters to us

Modern slavery means forcing or tricking someone into work through threats, deception or abuse of power. Construction is a higher-risk sector because so much work is subcontracted, and because it relies on agency and migrant labour across multiple layers of suppliers.

Most of our trades are engaged as subcontractors rather than direct employees, so our biggest risk area is who we choose to work with and how well we check them. This policy focuses on that.

  1. Who is responsible

Aaron Humber and Mark Hillman, as Directors, are jointly responsible for this policy, for making sure it is followed, and for reviewing it each year. Site managers and supervisors are responsible for applying it day to day, including on site.

  1. Checking subcontractors, agencies and suppliers

Before we engage a new subcontractor, trade contractor, recruitment agency or supplier, we will, where reasonable for the size of the job:

  • Check the business is genuine and properly registered (e.g. Companies House, and a valid GLAA licence where one is legally required).
  • Get written confirmation that they follow this policy, or an equivalent standard, as a condition of working with us.
  • Include anti-slavery terms in subcontracts and purchase orders, with the right to audit and to end the contract for breach.
  • Check that workers on our sites have the right to work in the UK.
  • Check that workers are paid directly, at or above minimum wage, with no unlawful deductions, and that no one has had ID or travel documents taken from them.
  • Reserve the right to visit sites unannounced and speak to workers directly.
  • Require subcontractors to apply the same standards to anyone they in turn engage.

Continuing to work with us depends on meeting these standards. If a subcontractor, agency or supplier does not comply, or will not cooperate with checks, we may suspend or end the contract and report the matter to the relevant authorities.

  1. Direct employment

Where we employ people directly, we will:

  • Use only reputable, licensed agencies to recruit.
  • Check identity, age and right to work before anyone starts.
  • Never charge a worker a fee to get a job with us.
  • Pay wages directly into the worker’s own bank account.
  • Never hold onto anyone’s ID, passport or travel documents.
  1. Spotting the signs

Site managers and staff should watch for signs such as:

  • Workers who seem frightened, withdrawn, malnourished, or show signs of abuse.
  • Workers with no ID, bank card or personal belongings of their own, or who can’t answer basic questions about their pay or hours.
  • A worker always transported and supervised by the same person, and unable to speak freely.
  • Workers living at the workplace or in overcrowded accommodation provided by an employer or agency.
  • Wages paid to someone other than the worker, or unexplained deductions.
  • A worker who says they owe money to a recruiter or employer for transport, accommodation, or finding them the job.

This list isn’t exhaustive. If something feels wrong, report it — see Section 7.

  1. Reporting a concern

If you think modern slavery may be happening in our business or supply chain, or you suspect a breach of this policy, report it to Aaron Humber or Mark Hillman. If your concern involves either director, report it instead to the Modern Slavery Helpline on 08000 121 700, or to the Gangmasters and Labour Abuse Authority (GLAA).

You can report in confidence, and anonymously if you prefer. We will take every report seriously, investigate promptly, and take appropriate action — which may include removing someone from site, ending a contract, or reporting to the police or GLAA. No one will be penalised for raising a genuine concern in good faith, even if it turns out to be mistaken.

  1. Training

Directors, site managers and anyone involved in choosing subcontractors or suppliers will be trained to recognise the signs of modern slavery, understand our checks, and know how to report a concern.

  1. Making sure people know about this policy

This policy is available to all staff and will be shared with subcontractors, agencies and suppliers as part of onboarding. Compliance with it is a standard condition in our subcontracts and purchase orders.

  1. Breaches

An employee who breaches this policy faces disciplinary action, up to and including dismissal. We may end our relationship with any subcontractor, supplier or agency found to be in breach, and report the matter to the relevant authorities where appropriate.

  1. Review

Aaron Humber and Mark Hillman will review this policy at least once a year and update it as needed. Last reviewed: 21 August 2026. Next review due: 21 August 2027.