This policy applies to all employees, contractors, agency staff, suppliers, business partners, and any other individuals or organisations working on behalf of or with our company. It governs our operations in all locations and extends to our global supply chain, recognising the complex and multi-layered nature of modern slavery risks.

 

The Wild Water Group means Alco Team Ltd, Wild Water Warehousing Ltd, Wild Water Frozen Ltd, Wild Water Storage Ltd, Wild Water Cold Storage Ltd and/or Wild Water Transport Ltd

  

AIM OF POLICY

Modern Slavery includes slavery, servitude, forced and compulsory labour, and human trafficking. Human trafficking involves the recruitment, transportation, transfer, harbouring, or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, or abuse of power for the purpose of exploitation.

 

The Wild Water Group has a zero tolerance for modern slavery and human trafficking within our business and supply chains. We are committed to acting ethically and with integrity in all business dealings and relationships. We will implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

 

Legal Framework

Our policy aligns with international conventions and national legislation, including but not limited to:

• The UK Modern Slavery Act 2015

• The United Nations Universal Declaration of Human Rights

• The International Labour Organization (ILO) Conventions

• Other relevant local laws in jurisdictions where we operate.

 

Governance and Accountability

We maintain clear internal accountability for the implementation and oversight of this policy:

• The Board has ultimate responsibility for ensuring compliance with modern slavery legislation and for approving the annual Modern Slavery Statement.

• A designated Modern Slavery Lead is responsible for:

  • Overseeing policy implementation

  • Monitoring risk assessments and due diligence processes

  • Reporting to the Board on modern slavery risks and actions

• Senior management are responsible for embedding this policy within their departments and ensuring operational compliance.

We will:

• Review modern slavery risks and controls at least annually at Board level.

• Maintain internal reporting mechanisms to track concerns, incidents, and actions.

• Ensure accountability through performance and compliance monitoring.

   

Risk Management and Safe Working Environment

We recognise that a safe, inclusive, and transparent working environment is critical to preventing modern slavery risks. To support this, we maintain policies and procedures including:

• Equality, Diversity, and Inclusion Policy – to promote fairness and prevent discrimination.

• Dignity at Work / Anti-Harassment Policy – to ensure respectful treatment of all workers.

• Health and Safety Policy – to safeguard worker wellbeing

• Grievance and Whistleblowing Policies – to enable safe reporting of concerns.

• Right to Work and Employment Checks Procedures

We are actively:

• Monitor working conditions across all sites.

• Encourage open communication between workers and management.

• Ensure workers understand their rights and feel safe raising concerns.

• Take a zero-tolerance approach to intimidation, coercion, or exploitation.

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Employees and Recruitment Practices

• We are committed to ensuring that all recruitment practices are fair, transparent, and free from exploitation. To mitigate the risk of modern slavery within our direct workforce, we will:

• Conduct pre-employment checks, including right-to-work verification and identity checks, in line with UK legal requirements.

• Where appropriate, undertake background screening to validate employment history and reduce the risk of exploitation or coercion.

• Ensure that all recruitment—whether direct or via agencies—is conducted ethically, with no worker-paid recruitment fees.

• Only engage reputable recruitment agencies that demonstrate compliance with modern slavery legislation and ethical labour standards.

• We are committed to fair pay and ethical employment practices and will:

  • Pay all employees at least the National Minimum Wage, with a commitment to progressing toward or maintaining Living Wage employer standards.

  • Ensure wages are paid directly to workers and not withheld or manipulated.

  • Provide clear and transparent payslips detailing earnings and deductions.

 

Organisational structure and supply chains

The Company provides storage and distribution services throughout South Wales and Southwest England and recognises that we operate in a domain that could be susceptible to the risks of modern slavery and human trafficking, primarily because we operate HGV vehicles that move across England and Wales, including UK ports.

 

Our operating countries are:

• Wales, United Kingdom

• England, United Kingdom

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Supplier Code of Conduct

All suppliers and business partners are expected to uphold standards consistent with our Modern Slavery Policy which includes, but is not limited to:

• Prohibiting the use of forced, bonded, or involuntary prison labour.

• Ensuring all work is voluntary and that workers are free to leave upon reasonable notice.

• Prohibiting child labour and requiring adherence to minimum working age laws.

• Providing fair wages, working hours, and humane working conditions.

• Respecting workers’ freedom of association and right to collective bargaining.

• Maintaining transparent recruitment practices and prohibiting worker-paid recruitment fees.

• Regularly monitoring and reporting on compliance with these standards.

  

To mitigate risks in our supply chain we will:

 

Manage our supplier data with a complete and up to date list of suppliers, including providers of both goods and services which will include:

• The supplier’s name and address

• What type of good or service they provide to you

• How much you spend annually on them.

 

If any of key suppliers operate in sectors or countries that are ‘high risk’ for modern slavery we will ensure that they have their own policy and procedures in place to mitigate the risks and check on this with them regularly.

 

We conduct due diligence on new and existing suppliers, including risk-based assessments, audits where appropriate, and ongoing monitoring of compliance with our Modern Slavery Policy. 

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Training and Awareness

We recognise that raising awareness and building capacity are vital to combating modern slavery. We commit to:

• Providing regular training to employees, especially those in procurement, HR, and supply chain roles, to help them identify signs of modern slavery.

• Offering guidance and resources to contractors, suppliers, and partners to encourage compliance and initiative-taking risk management.

• Promoting awareness of modern slavery issues throughout the organisation via communications, posters, and workshops.

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Reporting and Whistleblowing

We encourage all employees, suppliers, contractors, and other stakeholders to report any concerns about modern slavery or human trafficking in our business or supply chains. Reports can be made confidentially and without fear of retaliation via:

• A dedicated email address (hr@wildwatergroup.com)

• Direct reporting to line managers or senior management

• External reporting channels as appropriate under law

• All reports will be investigated promptly and thoroughly, and appropriate remedial action will be taken.

 

Remediation and Escalation

Where a risk or instance of modern slavery is identified, we will take immediate and proportionate action:

 

Escalation Process

• All concerns will be escalated to senior management and the designated Modern Slavery Lead

• High-risk cases will be reported to the Board.

• Where appropriate, issues will be reported to relevant authorities, including law enforcement.

 

Remediation Actions

We are committed to prioritising the welfare of affected individuals. Actions may include:

• Ensuring individuals are removed from situations of harm.

• Working with specialist organisations, NGOs, or authorities to provide support

• Reviewing and strengthening internal controls to prevent recurrence

 

Supplier non-compliance

• Immediate investigation of any supplier suspected of breaches.

• Requirement for corrective action plans within defined timeframes

• Termination of supplier relationships where serious breaches are identified.

 

We will document all incidents, actions taken, and lessons learned to support continuous improvement.

 

The Company's Code of Conduct (found in the Colleague Handbook) makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain. Our Raising Concerns at Work Policy and Procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

 

Continuous Improvement

We are committed to the ongoing review and improvement of our modern slavery policy and practices. This includes:

• Annual reviews of policy effectiveness and emerging risks.

• Updating risk assessment and due diligence procedures, as necessary.

• Seeking feedback from employees, suppliers, and external stakeholders.

• Participating in industry initiatives and collaborations to improve standards across sectors.

 

Modern slavery is a complex and evolving challenge that requires ongoing vigilance, commitment, and collaboration. Through this policy, we reaffirm our determination to act ethically, to respect human rights, and to promote dignity and justice for all. Everyone within our business and supply chains is responsible for upholding these values, ensuring that together we create an environment free from exploitation and abuse.

 

Examples Of Labour Market Infringement

• Non payment of minimum wage

• Lack of personal protective equipment (PPE)

• Few or no breaks

• Demeaning treatment

• Long working hours

 

Examples Of Forced Labour

• Worker is controlled, forced, or coerced to perform work.

• No payment, withholding of wages or excessive wage reductions.

• Retention of identity documents or valuable possessions

• Restriction of movement or confinement to the workplace

• Threat of denunciation to authorities (mainly illegal migrant workers)

 

All situations that stray from decent work should be considered. They represent illegal activity and may reflect something more sinister going on.

 

Vulnerable workers

Vulnerable workers are those who are at risk of having their workplace entitlements denied, or who lack the capacity or means to secure them (HSE). They are usually employed in low-skilled, low-paid jobs with little job security. There are several factors that may put a person at risk of being exploited.

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Mitigating risks affecting our direct workers

Unfortunately, modern slavery can occur in the workforce without employers’ knowledge, despite best efforts.

 

To mitigate this, the Company will:

• promote awareness of rights.

• Provide every worker with a written contract in a language they understand. The contract will include:

  • Working hours

  • Pay and overtime rates.

  • Deductions (if any and including clear concepts)

  • Holiday and sick pay entitlements

  • Accommodation arrangements (if applicable)

 

Raise awareness among our workers about their rights through.

• displaying workers’ rights posters in the communal areas at each site.

• Share information about unions with as workers have the right to freedom of association.

• Raise awareness of the risks of modern slavery and the signs to look out for.

• Have clear procedures and communication channels with our workers so they can report.

concerns (grievances and whistleblowing) and share these with them on a regular basis.

• Where appropriate, policies and procedures can be translated into workers’ native languages.

• We will ensure that those recruiting workers on our behalf do not charge fees to secure a job at your business.

• Check our workers have access to their identification and visa documents at all times.

 

Agency Workers - Mitigating risks

Labour providers play a vital role in our business to assist with absence and peak demand on a site by site basis.

However, we recognise that using labour providers can increase the risk of exploitation within our workforce since it blurs oversight and accountability, especially when labour providers outsource to other labour providers.

 

To mitigate these risks, the company will:

• Key supplier checks before engaging with the labour provider.

• Conduct checks of agency worker documentation.

• Engage regularly with agency workers.

 

In addition, we ensure that our labour providers uphold the same working standards as ourselves and we treat agency workers the same as our direct workers.