Anti-Slavery & Human Trafficking Policy

Company Name: Be Clean Services Limited
Company Registration Number: 15045016
Registered Office: Flat 3, 44a Cavendish Street, Manchester, M15 6BQ
Director: Ludiata Wasansua
Policy Owner: Director
Effective Date: 14 October 2026
Review Date: 14 October 2027
Version: 1.0

1. POLICY STATEMENT

Be Clean Services Limited (“the Company”) is committed to conducting its business ethically, responsibly and with integrity. The Company has a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude and all forms of exploitation.

The Company recognises that modern slavery is a serious violation of fundamental human rights and may occur in businesses, workplaces and supply chains in various forms.

This policy sets out the principles and procedures adopted by Be Clean Services Limited to prevent, identify and address the risk of modern slavery and human trafficking within its business operations and supply chains.

The Company expects all employees, agency workers, contractors, subcontractors, suppliers and other business partners to uphold these principles and comply with applicable legislation.

2. PURPOSE AND SCOPE

The purpose of this policy is to:

Prevent modern slavery and human trafficking within the Company’s operations and supply chains.
Protect the rights, dignity and welfare of all workers.
Promote fair recruitment and employment practices.
Ensure that employees and business partners understand their responsibilities.
Provide a clear process for reporting suspected cases of exploitation.
Encourage transparency, accountability and continuous improvement.

This policy applies to all directors, employees, temporary workers, agency workers, contractors, subcontractors, suppliers and any other individuals or organisations acting on behalf of Be Clean Services Limited.

3. LEGAL FRAMEWORK

The Company is committed to complying with applicable UK laws relating to modern slavery, human trafficking, employment and the protection of workers, including:

The Modern Slavery Act 2015.
The Human Rights Act 1998.
Applicable UK employment legislation.
Applicable national minimum wage and working time requirements.
Relevant health and safety and equality legislation.

The Company will review this policy when necessary to reflect changes in legislation, regulatory guidance or business operations.

4. DEFINITION OF MODERN SLAVERY

For the purposes of this policy, modern slavery includes, but is not limited to:

4.1 Forced Labour

Work or services that a person is compelled to undertake against their will through threats, coercion, intimidation, debt or other forms of control.

4.2 Human Trafficking

The recruitment, transportation, transfer, harbouring or receipt of people for the purpose of exploitation.

4.3 Servitude and Slavery

Situations in which individuals are controlled, treated as property or forced to provide services without genuine freedom.

4.4 Debt Bondage

Situations in which workers are trapped in work through debts, recruitment fees or other financial obligations that they cannot reasonably repay.

4.5 Exploitation of Vulnerable Workers

Any practice involving the abuse of a person’s vulnerability, immigration status, financial circumstances, language difficulties or lack of knowledge of their employment rights.

5. COMPANY COMMITMENTS

Be Clean Services Limited is committed to the following principles:

No form of slavery, forced labour or human trafficking will be knowingly tolerated within the Company’s operations.
All employment must be freely chosen, and workers must be free to leave employment in accordance with applicable contractual and legal requirements.
Workers must receive fair and lawful remuneration.
No worker will be required to surrender their identity documents as a condition of employment.
The Company will not tolerate threats, intimidation, violence or coercion against workers.
Recruitment practices must be fair, transparent and lawful.
Workers must be treated with dignity, fairness and respect.
The Company will take appropriate action where credible concerns or evidence of exploitation are identified.

6. EMPLOYMENT AND RECRUITMENT PRACTICES

The Company will take reasonable and proportionate steps to ensure that recruitment and employment arrangements are conducted ethically.

These steps may include:

Verifying the identity and right to work of employees in accordance with UK law.
Providing clear information about job responsibilities, pay, working hours and employment terms.
Ensuring that workers understand the terms and conditions of their employment.
Prohibiting recruitment practices involving coercion, deception, threats or unlawful fees.
Monitoring the use of recruitment agencies and labour providers where applicable.
Ensuring that workers are paid in accordance with applicable legal requirements.
Maintaining appropriate employment and payroll records.
Providing workers with a safe and accessible way to raise concerns.

The Company will not knowingly employ or engage individuals through arrangements involving forced labour, trafficking or other forms of unlawful exploitation.

7. SUPPLIER AND CONTRACTOR RESPONSIBILITIES

The Company recognises that modern slavery risks may exist within supply chains, including the supply of cleaning products, equipment, uniforms, personal protective equipment and outsourced labour.

Where appropriate and proportionate to the nature of the business relationship, the Company will:

Expect suppliers and contractors to comply with applicable modern slavery legislation.
Assess suppliers for relevant ethical and labour risks.
Request information about recruitment and employment practices where appropriate.
Consider the use of contractual clauses addressing modern slavery.
Investigate credible concerns involving suppliers or subcontractors.
Take appropriate corrective action where breaches are identified.
Suspend or terminate business relationships where serious exploitation is identified and the circumstances justify such action.

The Company expects its business partners to maintain appropriate employment standards and to take reasonable steps to prevent modern slavery within their own operations and supply chains.

8. RISK ASSESSMENT AND DUE DILIGENCE

The Company will take a proportionate, risk-based approach to identifying and managing modern slavery risks.

Relevant risk factors may include:

The use of temporary, agency or subcontracted labour.
Recruitment through third-party labour providers.
Workers who may be vulnerable because of language barriers or financial circumstances.
Unusually low prices or labour costs that may indicate exploitation.
Unexplained deductions from wages or recruitment-related debts.
Restrictions on workers’ freedom of movement or access to identity documents.
Suppliers operating in sectors or locations associated with elevated labour exploitation risks.

Where risks are identified, the Company will consider appropriate measures to investigate, mitigate and monitor those risks.

9. IDENTIFICATION OF WARNING SIGNS

Employees, managers and business partners should remain alert to possible indicators of modern slavery, including:

Workers appearing fearful, intimidated or unable to speak freely.
Individuals being controlled by another person in relation to work or accommodation.
Workers being paid less than agreed or experiencing unexplained wage deductions.
Workers being forced to work excessive hours or prevented from taking appropriate breaks.
Threats of dismissal, violence, deportation or other consequences used to control workers.
Workers having their passports or identity documents withheld against their wishes.
Evidence of debt bondage, coercive recruitment or restrictions on leaving employment.

These indicators do not automatically establish that modern slavery has occurred. However, any reasonable concern must be taken seriously and reported promptly.

10. REPORTING CONCERNS

All employees, contractors, suppliers and other relevant parties are encouraged to report suspected modern slavery or human trafficking.

Concerns should be reported to:

Designated Contact: Ludiata Wasansua, Director
Company: Be Clean Services Limited
Registered Office: Flat 3, 44a Cavendish Street, Manchester, M15 6BQ

Concerns should be reported as soon as reasonably practicable, providing relevant details where it is safe to do so.

Reports will be treated sensitively and handled as confidentially as reasonably possible, subject to applicable legal obligations and the need to protect individuals.

No individual should attempt to investigate suspected trafficking or confront a suspected perpetrator if doing so could place themselves or another person at risk.

Where a person is in immediate danger, the police should be contacted on 999. Non-emergency concerns can be reported to the police on 101 or to the appropriate UK authorities.

11. PROTECTION AGAINST VICTIMISATION

The Company will not tolerate retaliation against any person who raises a concern in good faith, reports suspected exploitation or assists with an investigation.

No worker should be dismissed, threatened, disadvantaged or subjected to harassment for making a genuine report.

The Company will take appropriate action to address victimisation and will seek to ensure that concerns are handled fairly and responsibly.

12. TRAINING AND AWARENESS

The Company will communicate this policy to relevant employees and, where appropriate, contractors and suppliers.

Depending on the size and nature of its operations, the Company may provide guidance or training to help individuals:

Understand what modern slavery and human trafficking involve.
Recognise warning signs of exploitation.
Understand their reporting responsibilities.
Apply ethical recruitment and employment practices.
Understand the Company’s expectations of suppliers and contractors.

Training and awareness arrangements will be reviewed as appropriate to the Company’s activities and identified risks.

13. INVESTIGATION AND CORRECTIVE ACTION

All credible concerns will be assessed promptly and proportionately.

Where appropriate, the Company will:

Assess the immediate safety and welfare of any potentially affected individual.
Consider whether emergency services or relevant authorities should be contacted.
Preserve relevant information and records where lawful and appropriate.
Investigate the concern without placing individuals at additional risk.
Take appropriate employment, contractual or supplier-related action.
Review existing controls and introduce improvements where necessary.

The Company will take a victim-centred approach, prioritising the safety, dignity and welfare of affected individuals.

14. RESPONSIBILITIES

The Director

The Director, Ludiata Wasansua, is responsible for overseeing this policy, promoting compliance and ensuring that reported concerns receive appropriate attention.

Employees

Employees must comply with this policy, treat colleagues fairly, remain alert to potential exploitation and report concerns promptly.

Contractors and Suppliers

Contractors and suppliers are expected to comply with applicable laws, maintain ethical labour practices and cooperate reasonably with appropriate enquiries into suspected exploitation.

15. MONITORING AND REVIEW

The Company will review this policy at least annually and whenever significant changes occur in its operations, supply chains or applicable legal requirements.

Where appropriate, the Company may monitor:

The completion of relevant staff awareness activities.
The assessment of higher-risk suppliers and labour providers.
The number and nature of concerns raised.
Corrective actions taken in response to identified risks.
Improvements made to recruitment and supply-chain controls.

The Company will seek to improve its arrangements over time and address weaknesses identified through reviews or investigations.

16. MODERN SLAVERY STATEMENT AND LEGAL APPLICABILITY

This document establishes the Company’s anti-slavery and human trafficking policy. It does not, by itself, constitute confirmation that every part of the Company’s operations or supply chain has been independently audited.

Under section 54 of the Modern Slavery Act 2015, the statutory annual modern slavery statement requirement generally applies to commercial organisations carrying on business in the UK that supply goods or services and have a total annual turnover of at least £36 million, subject to the statutory conditions.

If the Company is below the applicable threshold, it may still adopt and maintain this policy voluntarily as evidence of its commitment to responsible business practices and ethical supply chains.

Where the statutory requirements apply, the Company will take appropriate steps to prepare, approve, sign and publish the required annual statement in accordance with the law.

17. APPROVAL AND AUTHORISATION

This policy is adopted by Be Clean Services Limited and approved for implementation by its Director.

For and on behalf of Be Clean Services Limited

Name: Ludiata Wasansua
Position: Director
Signature: __________________________________

Date: _______________________________________

Next Review Date: 14 October 2027

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