1. Introduction

The aim of this policy is to mitigate against slavery and human trafficking in ®Working at Height Limited® corporate activities, and to ensure our relationships and supply chains are free from labour crime.

As leading specialists in Education, Equipment, Consultants & auditors in Health, Safety, Welfare, Emergency & Advanced Rescue, operating in all business sectors worldwide, ®Working at Height Limited® and its subsidiaries (the Company) recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Modern Slavery refers to offences of human trafficking, slavery, servitude and forced bonded or compulsory labour. It is a violation of human rights.  

Human Trafficking involves the recruitment, harbouring or transportation of people into a situation of exploitation through the use of violence, deception, coercion or forced into a situation to work against their will.  

2. Responsibilities

It is the responsibility of all stakeholders, internal and external, including the Company’s employees, contractors, sub-contractors and suppliers to maintain the highest ethical standards and eliminate any malpractice. 

We are committed to preventing modern slavery of all forms, we have a zero tolerance approach and we expect the same high standards from those we work with in the conduct of our business. 

3. Procedure

The Company aims to conduct all business in an honest and ethical manner and to comply with all applicable legislation and regulations in the territories in which we operate.

Through a process of risk analysis the Company has identified the activities it conducts which may be at risk of modern slavery and human trafficking. The Company has put multiple procedures in place to safeguard against slavery and human trafficking in its operations globally. While not aiming to cover every scenario the following steps are carried out by the Company and to mitigate against labour crime in its operations. This list will be reviewed, monitored and updated on a recurring basis.

• All suppliers and sub-contractors of ®Working at Height Limited® are requested to complete a Approved Quality Supplier “AQS approval form” outlining compliance.
• ®Working at Height Limited® shall supervise compliance and reserves the right to investigate any concerns which may be raised.
• Continuous audits of policy and procedures in relation to modern slavery and human trafficking will be conducted utilising both internal and external auditors.

4. Raising a concern

The Company provides a mechanism for raising concerns and hopes that in the event an employee or subcontractor has knowledge or suspicion of slavery or human trafficking they have a moral and statutory obligation to raise such concerns with their line manager. In the event that the concerned party is not in a position to highlight their concern with their own line manager, they may contact their line manager’s manager, or a member of the Company’s senior management team.

Any concern can also be raised through the Company’s dedicated confidential email system: [email protected]

These email account is monitored by all members of the Senior Management Team.  All concerns will be investigated efficiently and promptly and where possible by our independent auditor.

5. Our policies

The Company has a number of procedures relating to employment practices which run in parallel to this policy. The Company operates the following policies that describe its approach to the identification of modern slavery, risks and steps to be taken to prevent modern slavery and human trafficking in its operations:

Whistleblowing Policy The Company is committed to the highest standards of openness, integrity and accountability, as well as the highest possible ethical standards in all of its practices. To achieve this, it encourages staff to use internal mechanisms for reporting any malpractice or illegal acts or omissions by its employees. We therefore view it as extremely important to have a mechanism in place to enable staff to voice concerns in a responsible and effective manner.

Ethics Policy The Company insists on the highest ethical standards when conducting business. Doing the right thing and acting with integrity are two of the driving forces behind the Company’s great success story. When faced with ethical issues, employees are expected to make the correct professional decision consistent with the Company’s principles and standards.

Equal Opportunities the Company is an Equal Opportunities Employer. As such it is committed to Equality of Opportunity for existing and potential employees. The purpose of our Equal Opportunity/Diversity Policy is to create a workplace which provides for Equal Opportunities for all staff and potential staff and where their dignity is protected and respected at all times. 

Recruitment and Selection the Company operates a robust Recruitment & Selection Procedure in line with legislation and employment laws. This includes right to work, employment and documentation checks. 

Supplier Code of Conduct the Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Company works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. We have a zero tolerance approach to violation of this policy. The Company will review the continuation of business with individuals and organisations found to in violation of this policy and reserve the right to terminate business with such suppliers on this basis. 

6. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to relevant members of staff. All staff have been notified of this policy.

7. Our Performance Indicators

An indication that the measures/steps we have put in place to mitigate against human trafficking & modern slavery in our operations are sufficiently working will result in:  

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

®Working at Height Limited® will continue to develop and implement the measures mentioned above in respect of our supply chain.

Our approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2024 and beyond.

This statement also constitutes the Company’s (European Entities) required statement purseant of Directive 2011/36/EU of the European parliament  Title 1, Article 5 the 2011 directive on Slavery / Forced Labour for the current financial year. 

This statement also constitutes the Company’s (UK Entities) required statement purseant to Section 54(1) of the Modern Slavery Act 2015 on slavery and human trafficking for the current financial year. 

This statement also constitutes the Company’s (Austrailen Entities) required statement purseant of the Modern Slavery Act 2018 on slavery and human trafficking for the current financial year. 

This statement also constitutes the Company’s (USA Entities) required statement purseant to US Code – Title 18 Sections § 1581 to § 1594 of The United Consatution 1789 (Rev 1912) on slavery and human trafficking for the current financial year. 

This statement also constitutes the Company’s (Canadan Entities) required statement purseant of the Modern Slavery Act or Supplychains Act 2023 on slavery and human trafficking for the current financial year.