Modern Slavery Act Policy

WhMTHL Fleet Services

1. Purpose and Commitment

Our organisation is committed to preventing modern slavery, human trafficking, forced labour, debt bondage, servitude, and child labour in all areas of our business and supply chain. We uphold the principles of the Modern Slavery Act 2015, ensuring transparency, ethical conduct, and respect for human rights.

We recognise our responsibility to act ethically and with integrity in all business relationships and to implement effective systems and controls to ensure modern slavery is not taking place anywhere in our operations.

2. Scope

This policy applies to:

• All employees, contractors, temporary workers, and agency staff

• All suppliers, subcontractors, and service providers

• All business units, subsidiaries, and operational sites within the UK and internationally

3. Legal Framework

This policy is guided by:

• Modern Slavery Act 2015 (Section 54 – Transparency in Supply Chains)

• UK Government guidance on modern slavery statements and supply chain transparency

• International labour standards relating to forced labour and human trafficking

Where required, our organisation will publish an annual Modern Slavery Statement if our turnover meets the statutory threshold of £36 million or more.

4. Roles and Responsibilities

• Board of Directors / Senior Leadership Approve the policy, oversee compliance, and review annual progress.

• Modern Slavery Compliance Lead Responsible for risk assessments, supplier due diligence, training, and reporting.

• Managers and Supervisors Ensure day to day compliance and escalate concerns.

• Employees and Contractors Must follow this policy and report any suspected breaches.

5. Risk Assessment

We conduct regular assessments to identify areas of potential modern slavery risk, including:

• Labour intensive activities

• Use of temporary or migrant labour

• High risk countries or sectors

• Multi tier supply chains where visibility is limited

Risk levels are categorised and reviewed annually.

6. Supplier Due Diligence

We expect all suppliers to operate ethically and comply with modern slavery laws. Our due diligence includes:

• Supplier onboarding questionnaires

• Verification of labour practices

• Review of supplier policies and certifications

• Risk based audits and site visits

• Contractual obligations requiring compliance with this policy

Suppliers failing to meet our standards may be suspended or removed.

7. Contractual Controls

All supplier and contractor agreements include:

• Anti slavery and human trafficking clauses

• Requirements for transparency and cooperation in audits

• Immediate termination rights for non compliance

• Obligations to cascade these requirements to their own supply chains

8. Training and Awareness

We provide training to:

• Employees involved in procurement, HR, operations, and supply chain management

• Managers responsible for recruitment or contractor engagement

Training covers recognising signs of modern slavery, reporting procedures, and legal obligations.

9. Reporting Concerns & Whistleblowing

We maintain clear reporting channels for concerns:

• Anonymous whistleblowing

• Direct reporting to the Modern Slavery Compliance Lead

• Protection for whistleblowers from retaliation

All reports are investigated promptly and confidentially.

10. Remediation

If modern slavery is identified:

• We will take immediate action to safeguard affected individuals

• Work with authorities and specialist organisations where appropriate

• Review and strengthen controls to prevent recurrence

• Terminate relationships with suppliers unwilling to remediate issues

11. Monitoring & Review

We track:

• Number of supplier audits completed

• Training completion rates

• Reported incidents and outcomes

• Improvements in supply chain transparency

This policy is reviewed annually and updated to reflect new legislation, guidance, and best practice.

12. Approval

This Modern Slavery Act Policy has been approved by the Board of Directors and will be reviewed annually.

Contact and further information
If you have any questions about this notice, please email us at service@mthlfleetservices.com or write to us at our registered office address: MTHL Fleet Services, 391 Viscount Way, Heathrow. TW6 2JD.