Modern Slavery Statement Rev February 2024

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that we at The London Window Cleaner (The Company), part of the Hammersmith Works LTD group, have taken and are continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Company has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

The London Window Cleaner has been at the forefront of providing innovative and safe access solutions for high level cleaning around the Capital for the last decade.  Our staff are drawn from a broad international background, forming a united team of specialist cleaners delivering high quality services.

Areas of Risk

With stringent employment policies and careful background checks on staff, we note that the area of greatest risk is through our supply chain.  As such we have a limited range of carefully vetted, mainstream suppliers.  We expect all of these companies to have a similar policy in place and an auditable system of works to show their adherence thereto.

Our Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
2. Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
3. Whistle-blowing policy. We operate a whistle-blowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of negative treatment.
4. Suppliers Code of business conduct. This policy sets out the manner in which we expect our business partners and suppliers to act in their business dealings and their ethical approach to business conduct.

Our suppliers

The Company operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier.  This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

1. They have a policy on Modern Slavery
2. They hold their own suppliers to account over modern slavery
3. (For UK based suppliers) They pay their employees at least the national minimum wage or ideally are part of the Living Wage Foundation.
4. (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
5. We may terminate the contract at any time should any instances of modern slavery come to light

Training

Whilst our procurement chain is small, we regularly discuss our policy to ensure that all involved in buying understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

Our performance indicators

We will monitor the effectiveness of this policy and the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain.  We will determine that we have taken sufficient steps provided:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Approval for this statement

This statement was approved by the Board of Directors on April 6th 2016.  The policy is reviewed and updated annually.

Christopher Turner
Managing Director

[email protected]
Freephone: 0800 633 5779

HSEQ Documentation: Modern Slavery Policy