Modern Slavery and Human Trafficking Statement 2025

Waste Collection Westminster is committed to conducting all aspects of its business ethically, responsibly, and in full compliance with applicable laws. This Modern Slavery and Human Trafficking Statement sets out the steps we take to prevent modern slavery and human trafficking in our operations and supply chains. It applies to all employees, agency workers, contractors, and suppliers engaged by Waste Collection Westminster.

Our Zero-Tolerance Approach

We have a zero-tolerance policy towards modern slavery, human trafficking, forced labour, child labour, and all forms of exploitation. We will not knowingly work with any organisation or individual involved in such practices. All commercial decisions, from procurement to service delivery, must align with this policy. Breaches of this policy are treated as serious misconduct and may result in disciplinary action, termination of contracts, and, where appropriate, reporting to relevant authorities.

Senior management is responsible for promoting a culture where respect for human rights is central to the way we operate. Every member of staff shares responsibility for identifying and escalating concerns relating to modern slavery in any part of our business or supply chain.

Our Operations and Supply Chains

Waste Collection Westminster provides waste and recycling collection services across Westminster, engaging a range of suppliers for vehicles, equipment, uniforms, technology, and specialist services such as subcontracted collections and maintenance. We recognise that supply chains linked to waste management, logistics, cleaning, and temporary labour can be at higher risk of labour exploitation. We are committed to understanding these risks and taking effective action to prevent harm.

Supplier Standards and Due Diligence

All new and existing suppliers are expected to meet our ethical standards and to comply with all laws relating to modern slavery and human trafficking. Our supplier onboarding process includes assessment of labour practices, health and safety standards, and the use of subcontractors. Where appropriate, we require contractual commitments confirming that suppliers prohibit forced, bonded, or involuntary labour and ensure fair treatment, wages, and working conditions.

We reserve the right to terminate relationships with suppliers that fail to meet these standards or do not demonstrate adequate and timely improvement when issues are identified.

Supplier Audits and Monitoring

Waste Collection Westminster undertakes a risk-based programme of supplier audits and monitoring. Higher-risk suppliers, such as those providing labour, uniforms, and outsourced operational services, may be subject to more frequent review. Audits may include site visits, interviews with workers where appropriate, review of employment records, and examination of working conditions.

Where non-compliance or areas of concern are identified, we work with suppliers to develop corrective action plans with clear timescales. Failure to implement agreed improvements can result in escalation, including suspension or termination of the business relationship.

Reporting Channels and Whistleblowing

We encourage anyone who becomes aware of modern slavery concerns in our operations or supply chains to report them without delay. Employees can raise concerns with their line manager, a senior manager, or through our confidential whistleblowing channel. Contractors, agency workers, and suppliers are similarly encouraged to report suspected exploitation to their primary contact at Waste Collection Westminster or to a senior manager.

All reports will be taken seriously, investigated promptly, and handled as sensitively as possible. We will not tolerate any form of victimisation or retaliation against individuals who raise concerns in good faith, irrespective of whether those concerns are ultimately substantiated.

Training and Awareness

Relevant staff, including managers, procurement teams, and supervisors responsible for on-site operations, receive training on modern slavery risks, recognising signs of exploitation, and using the reporting channels. Awareness materials are also made available to wider staff to support understanding of the issue and our expectations.

Continuous Improvement and Annual Review

We are committed to continually improving our approach to identifying and addressing modern slavery risks. Each year, we review the effectiveness of our policies, due diligence processes, supplier audits, and training. This review considers any incidents reported, the outcomes of investigations, and feedback from staff and suppliers.

This Modern Slavery and Human Trafficking Statement is reviewed and approved by the senior leadership of Waste Collection Westminster on an annual basis and updated as necessary to reflect changes in our business, legal requirements, and best practice. It represents our ongoing commitment to preventing modern slavery in all aspects of our work.