Modern Slavery & Human Trafficking Policy
Introduction
Modern slavery is a crime resulting in an abhorrent abuse of human rights. It is constituted in the Modern Slavery Act 2015 by the offences of ‘slavery, servitude and forced or compulsory labour’ and ‘human trafficking’.
Despite many organisations taking action to promote ethical business practices and policies that protect workers from being abused and exploited in their own organisation and global supply chains there are still far too many people in the world being treated as commodities. There are also far too many organisations ignoring such abuses or who are knowingly responsible for policies and practices that result in workers being subjected to modern slavery in their operations.
Purpose
The purpose of this policy is to affirm Water Direct’s commitment to preventing modern slavery and human trafficking in all its forms within our operations and supply chains. This policy outlines our approach to identifying, mitigating, and addressing risks related to modern slavery, ensuring compliance with relevant legislation, and promoting ethical business practices. By implementing this policy, we aim to protect the rights and dignity of all individuals involved in our business activities and to foster a culture of transparency, accountability, and respect.
Scope
This policy applies to Water Direct and its affiliates, regardless of geographical location. It covers all employees, contractors, suppliers, and business partners involved in our operations and supply chains. The policy encompasses all business activities, including procurement, supply chain management, and recruitment practices. It aligns with relevant legal and regulatory frameworks, including the Modern Slavery Act 2015 (UK). All departments and individuals within the organization are responsible for adhering to this policy.
Organisation’s Structure
Water Direct is the UK’s leading alternative and emergency water supplier, providing wholesome, quality assured bulk water supplies nationwide. We are a wholly owned subsidiary of Soris Acquisition Ltd. Water Direct Ltd has its head office in the United Kingdom. Water Direct Ltd employs approximately 92 members of staff and operates only in the United Kingdom. We have an annual turnover in excess of £10m.
Our Business
Our Business operates nationally from a number of depots throughout the United Kingdom, providing quality assured, wholesome, alternative water supplies in bottles, tanks and tankers and temporary infrastructure to create surrogate mains water supplies. Additional services include third party asset management, maintenance, and deployment as well as contingency planning for business continuity.
Our Supply Chains
Our supply chains primarily include obtaining both bulk potable and bottled water as well as potable water containers (and associated pumps, pipework and fittings) from a number of parties. We also work with a number of contractors who supply haulage, storage, technical testing and analysis along with general business support services.
Policy Statement
Water Direct is committed to procuring its works, goods and services in an ethical and environmentally sustainable way and take our obligations under the Modern Slavery Act 2015 (the “Act”) very seriously. We operate a zero-tolerance approach to any form of modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems with controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Act. We expect the same high standards from all our contractors, suppliers and other business partners and that our suppliers will hold their own suppliers to these same high standards.
Water Direct will not enter any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities. This includes article 4 of the Universal Declaration of Human rights, which states “No one shall be held in slavery or servitude; Slavery and the slave trade shall be prohibited in all their forms”.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this Policy.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 30 April 2024
Roles & Responsibilities
- C-Suite Executives (e.g., CEO, CFO)
– Align the organisation’s activities with the modern slavery policy.
– Oversee the implementation of the policy across all departments.
– Ensure that modern slavery risks are integrated into the company’s overall risk management
framework.
– Develop and implement strategies to meet the company’s CSR objectives, including modern slavery
prevention
– Integrate modern slavery risk factors into ESG strategies and reporting
– Approve changes to the policy. - Heads of Department
– Ensure compliance with modern slavery regulations within their areas of responsibility. - Third Party Legal Support Service
– Provide legal advice on compliance with modern slavery laws.
– Ensure that contracts with suppliers include clauses related to modern slavery prevention. - Head of Supply Chain
– Conduct periodic compliance audits of suppliers to ensure they adhere to modern slavery policies. - Human Resources Consultant
– Implement responsible recruitment practices to prevent forced labour.
– Provide training to employees on recognizing and reporting modern slavery. - Supply Chain Department
– Perform regular audits of supply chain records, processes, and procedures to identify potential risks. - Employees
– Be proactive in preventing and reporting suspected cases of modern slavery.
– Ensure procurement practices do not contribute to modern slavery.
Supporting Processes & Procedures
Communication & Awareness
Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Due Diligence Processes
We have in place a Policy to protect whistle blowers who highlight to us any risk of slavery or human trafficking within our business.
Training
Training on this Policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all employees. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we aim to develop and provide regular training for our staff.
Adam Johnson,
Chief Executive Officer
Revision Number: 03
Date of Issue: 07 Apr 2025