Modern Slavery & Human Trafficking Policy

VOGAL GROUP

Modern Slavery and Human Trafficking Policy

Issue Date: 1st November 2025
Review Date: November 2026

Version: 1.0
Approved By: Rob Gault – Managing Director

1. Policy Statement

Vogal Group is fully committed to preventing modern slavery, human trafficking, forced labour, and exploitation within our organisation, supply chain, and any business activities associated with our operations.

We uphold the principles of:

  • The Modern Slavery Act 2015
  • Human Rights Act 1998
  • International Labour Organisation (ILO) Standards
  • UN Guiding Principles on Business & Human Rights

We operate a zero-tolerance approach to modern slavery in all forms and expect the same high standards from all employees, subcontractors, suppliers, and business partners.

2. Objectives

Our objectives are to:

  • Ensure transparency, accountability, and ethical conduct across our business.
  • Prevent the use of forced, bonded, trafficked, or child labour.
  • Identify and mitigate the risk of modern slavery in our supply chain.
  • Ensure all workers have the right to work freely and legally.
  • Train staff to recognise signs of modern slavery.
  • Provide a safe and confidential method for reporting concerns.
  • Work only with suppliers committed to ethical and lawful practices.
  • Investigate and act on all concerns or allegations without delay.

3. Scope

This policy applies to:

  • All employees, agency staff, and temporary workers
  • Directors, managers, and supervisors
  • Subcontractors, labour providers, consultants, and intermediaries
  • Suppliers, manufacturers, and business partners
  • Any individual or organisation representing Vogal Group

It applies to all operations, both within the UK and internationally.

4. Definitions (Expanded)

4.1 Modern Slavery

Includes the following forms of exploitation:

  • Forced or compulsory labour
  • Human trafficking
  • Debt bondage
  • Child labour
  • Servitude
  • Forced marriage
  • Coerced labour through threats or deception

4.2 Human Trafficking

Recruitment, movement, or harbouring of a person by coercion or deception for the purpose of exploitation.

4.3 Forced Labour

Work or service extracted under threat, penalty, coercion, or without consent.

4.4 Child Labour

Employment of individuals under the legal minimum working age or in unsafe/harmful conditions.

4.5 Exploitation Indicators

Signs may include:

  • Confiscation of passports or ID
  • Fearful behaviour
  • Poor or unsafe living conditions
  • Excessive working hours
  • No employment contract
  • Debt bondage
  • Restricted movement
  • Lack of personal possessions
  • Cash payments withheld or controlled

Employees must remain vigilant for these signs.

5. Responsibilities

5.1 Managing Director

  • Ensure Company compliance with the Modern Slavery Act 2015.
  • Approve and review this policy annually.
  • Provide leadership on ethical practices and due diligence.
  • Ensure adequate resources are allocated.

5.2 Management & Supervisors

  • Carry out due diligence on labour providers and subcontractors.
  • Ensure all workers have valid right-to-work documentation.
  • Monitor site conditions and labour practices regularly.
  • Train staff on recognising signs of modern slavery.
  • Escalate concerns immediately.

5.3 Employees

Employees must:

  • Follow this policy and attend required training.
  • Report suspicions or concerns immediately.
  • Cooperate with investigations.
  • Never engage in behaviour that could enable exploitation.

They must NOT:

  • Ignore signs of exploitation
  • Employ or subcontract anyone illegally
  • Retain identity documents belonging to others

5.4 Suppliers & Subcontractors

All suppliers must:

  • Demonstrate ethical employment practices.
  • Provide evidence of compliance when requested.
  • Sign and return the Company’s Supplier Code of Conduct.
  • Undergo due diligence checks.
  • Ensure modern slavery controls in their own supply chains.

6. Risk Management & Due Diligence

Vogal Group will perform risk assessments on:

  • Labour agencies
  • Subcontractors
  • Overseas suppliers
  • High-risk products and materials (e.g., PPE, electronics, garments)
  • Low-skilled or temporary labour
  • Contractual arrangements involving recruitment or migration

Due diligence may include:

  • Right-to-work verification
  • Supplier self-assessment questionnaires
  • Modern slavery declarations
  • Supplier audits
  • Review of recruitment practices
  • Site inspections
  • Compliance checks with employment law

Suppliers demonstrating non-compliance may be:

  • Suspended
  • Removed from the supply chain
  • Reported to authorities

7. Safe Recruitment Practices

To prevent forced or illegal labour:

  • All employees must provide original ID and right-to-work documentation.
  • All workers must have a formal employment agreement.
  • Fees or charges must never be charged to workers for recruitment.
  • Labour-only subcontractors must follow the same rules.
  • Agency workers must be paid directly and legally.
  • No worker’s passport or personal documents may be held by the Company.

8. Training & Awareness

Vogal Group will ensure that:

  • All employees receive training on recognising signs of modern slavery.
  • Managers responsible for procurement and recruitment receive enhanced training.
  • Toolbox talks are delivered for site-based staff.
  • Suppliers are informed of our ethical expectations.
  • Refresher training is completed annually or when legislation changes.

 

9. Reporting Concerns

Any employee, subcontractor, or worker who suspects modern slavery must report it immediately to:

  • Their Manager
  • The Compliance / H&S Manager
  • The Managing Director

Reports may also be made through the Whistleblowing Procedure, anonymously if required.

Where there is immediate danger, employees must contact:

  • Police: 999 (emergency)
  • Modern Slavery Helpline: 0800 0121 700

All reports will be treated confidentially and investigated promptly.

10. Handling Reports & Investigations

The Company will:

  • Take all reports seriously
  • Ensure investigations are confidential and impartial
  • Protect those who report concerns
  • Cooperate fully with law enforcement agencies
  • Take swift action to remove risks or exploitation
  • Suspend or terminate suppliers/employees involved
  • Maintain written records of investigations and outcomes

Victimisation of individuals who raise concerns is prohibited.

11. Working Conditions & Welfare Standards

Vogal Group is committed to ensuring:

  • Safe and hygienic working environments
  • Fair wages and compliance with minimum wage regulations
  • Reasonable working hours and rest breaks
  • Access to clean facilities and welfare areas
  • No retention of personal identity documents
  • Freedom to leave employment with notice
  • No forced overtime

These standards must also be upheld by suppliers and subcontractors.

12. Supply Chain Compliance

The Company expects all partners to maintain:

  • Transparent labour practices
  • Ethical sourcing
  • Fair recruitment methods
  • Adequate supervision of migrant or temporary workers
  • Written contracts for all labour
  • Audit access where required

High-risk suppliers may be required to:

  • Complete ethical audit reports
  • Provide third-party certifications (e.g., SMETA, SA8000)
  • Demonstrate corrective actions
  • Undergo site visits

Suppliers failing to meet standards will be removed.

13. Monitoring, Audit & Review

Vogal Group will:

  • Monitor workforce and supply chain risks
  • Carry out regular audits on subcontractors and labour providers
  • Review procurement and recruitment processes
  • Analyse incident reports and trends
  • Review this policy annually
  • Implement corrective actions where required

14. Associated Documents

  • Whistleblowing Policy
  • Anti-Bribery & Corruption Policy
  • Recruitment & Vetting Procedure
  • Equality, Diversity & Inclusion Policy
  • Health & Safety Policy

END OF DOCUMENT

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