Modern Slavery Statement — Commercial Waste Greenwich
This Modern Slavery Statement sets out the commitment of Commercial Waste Greenwich and its affiliates to prevent modern slavery, human trafficking and forced labour in our operations and supply chains. We recognise our responsibility as a provider of Greenwich commercial waste solutions to maintain transparent procurement practices and to act with integrity. Our policy applies across all activities, including vehicle operations, waste collection, recycling services and subcontracted labour.
We operate a zero-tolerance policy towards any form of modern slavery. That means we will not knowingly engage with suppliers, contractors or partners who exploit workers, impose excessive working hours without compensation, withhold identity documents, or use coercion. The approach of CW Greenwich is to identify, investigate and remediate any suspected instances promptly and decisively.
To deliver on this commitment, our statement covers governance, risk assessment, supplier due diligence and reporting channels. The leadership team takes responsibility for ensuring this modern slavery policy is embedded into day-to-day operations and commercial decision-making for the commercial waste company in Greenwich and for supplier relationships beyond the borough.
Policy, Due Diligence and Supplier Audits
Our due diligence process includes risk-based supplier screening, contractual clauses that require compliance with anti-slavery laws, and scheduled supplier audits. Audits of key suppliers and subcontractors assess recruitment practices, working conditions, pay, and documentation. Where appropriate, we use site visits and third-party verifiers to corroborate self-assessments.
We maintain a structured supplier audit programme:
- Initial risk assessment at onboarding focusing on geography, labour intensity and subcontracting;
- Documentary checks including right-to-work and payroll validation;
- On-site inspections and interviews where risk indicators are identified;
- Corrective action plans with timelines and follow-up reviews.
Where audits reveal non-compliance, we require prompt remediation and monitor corrective action. In severe cases we will suspend or terminate contracts. We also support workers and subcontractor employees where exploitation is identified, working with local agencies and, where necessary, law enforcement to ensure safe outcomes.
Reporting Channels, Training and Annual Review
We provide multiple reporting channels for employees, suppliers and third parties to raise concerns about potential slavery or trafficking. Reports can be raised anonymously through internal whistleblowing mechanisms and are handled confidentially. All reports are investigated by a nominated compliance lead and escalated to senior management where appropriate.
Training is mandatory for staff with procurement, HR and operational responsibilities and is offered to driver crews and site supervisors to help spot signs of forced labour. We emphasise early detection and encourage a culture where people feel safe to speak up without fear of reprisal. Our engagement with industry groups and local partners strengthens awareness across the supply chain of CW Greenwich.
This Modern Slavery Statement will be reviewed annually. Each year we will publish the outcomes of our due diligence activities, supplier audits, remediation efforts and any policy updates. The review will consider evolving risks in the waste sector, lessons from incidents, and feedback from stakeholders. By continually monitoring performance, updating controls and increasing transparency, Commercial Waste Greenwich reaffirms its dedication to eliminating modern slavery from its operations and supply chains.
