Modern Slavery Statement — Commercial Waste Cobham Commitment

Company team inspecting waste facility near Cobham Commercial Waste Cobham is committed to combating modern slavery and human trafficking in all forms across our operations and supply chains. This Modern Slavery Statement sets out our approach, expectations and actions to ensure that our commercial waste services in Cobham and surrounding areas operate with integrity and respect for human rights. We recognise our responsibility to maintain high standards of ethical conduct and to enforce a zero-tolerance policy toward any form of forced labour, exploitation or coercion.

Our statement covers all employees, contractors and business partners engaged with Cobham commercial waste activities. It applies to permanent, temporary and agency workers and extends to third-party suppliers and sub-contractors in the commercial-waste Cobham network. We define modern slavery to include forced labour, bonded labour, human trafficking and other forms of severe exploitation.

Auditor reviewing supplier documents for waste services

Zero-Tolerance Policy

We maintain a clear, strong stance: no tolerance for slavery or labour exploitation. Any evidence of modern slavery within our operations or supplier base will trigger immediate action, including suspension of contracts, termination of engagement and referral to appropriate authorities where necessary. Our leadership ensures that compliance with this zero-tolerance policy forms part of senior management performance reviews and procurement objectives.

Due Diligence and Supplier Audits

Commercial Waste Cobham operates a risk-based due diligence programme to identify and mitigate slavery risks. We conduct pre-contract checks, ethical compliance questionnaires, and targeted supplier assessments for high-risk categories. Our supplier audits combine document reviews, site inspections and worker interviews to verify that labour standards meet our expectations.

Supplier Obligations

Suppliers providing commercial waste collection, disposal, recycling or ancillary services for Cobham must adhere to our code of conduct. Key requirements include:

Transparent recruitment practices and no recruitment fees for workers
Appropriate wages and working hours in line with legal requirements
Freedom of movement and no retention of identity documents
Access to grievance mechanisms and worker communication channels

Audit outcomes are graded and used to inform remediation plans. High-risk suppliers undergo more frequent inspections and are expected to implement corrective action plans within defined timeframes, or face contract termination.

Reporting Channels and Whistleblowing

Training session on modern slavery awareness for staff We promote multiple, confidential reporting channels so that concerns about potential slavery or exploitation can be raised safely. Employees and third parties can report issues through internal hotlines, secure email reporting systems and via designated compliance officers. Reports are handled promptly, with protections in place to prevent retaliation.

What to report: signs of forced or bonded labour, restricted movement, withheld pay, deception in recruitment, or poor living and working conditions. All reports are investigated by our compliance team and escalated to senior management when necessary.

Investigation and Remediation

Investigations are conducted impartially and may involve external experts. Where modern slavery is suspected or confirmed, we will take immediate remedial steps to protect victims, which may include safe relocation, provision of support services and collaboration with law enforcement. Contracts with non-compliant suppliers will be reviewed under our legal and commercial frameworks.

Training, Monitoring and Continuous Improvement

Supervisor discussing contract compliance with a supplier All staff involved in procurement, operations and human resources receive regular training on recognising signs of modern slavery and on our reporting procedures. We encourage a culture where employees are empowered to raise concerns without fear. Monitoring includes key performance indicators, supplier scorecards and periodic third-party assurance reviews.

Our approach to reducing the risk of slavery in the supply chain includes collaborative engagement with suppliers, industry initiatives, and the adoption of best practices in responsible sourcing across the Cobham commercial waste sector.

Documents and checklist used in annual policy review

Annual Review and Governance

We review this Modern Slavery Statement annually to assess effectiveness and to update policies and procedures. The senior leadership team and Board receive regular reports on modern slavery risks, audit findings and remedial actions. This annual review ensures our commitments remain robust and responsive to emerging risks in the commercial waste industry in and around Cobham.

Accountability: Ultimately, responsibility for this policy sits with senior management, supported by the compliance and procurement teams. We will continue to strengthen our safeguards and report transparently on progress.

Commercial Waste Cobham reaffirms its commitment to uphold human rights and eliminate modern slavery from its operations and supply chains. We will continue to work proactively with partners to ensure responsible, ethical management of commercial waste in Cobham and beyond.