Modern Slavery

360 Commercial Cleaning Ltd Modern Slavery Policy

The Modern Slavery Act 2015 (‘the Act’) creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking. 360 Commercial Cleaning Services Ltd are committed to supporting both the aims and the letter of the Act, namely, to combat all forms of modern slavery and human trafficking and to improve our practices across our group to help achieve this.

Our Business

360 Commercial Cleaning Services Ltd has been Trading since 2007. We only source our materials from fully accredited UK supplies.

Our People

In April 2022, we employ 65 employees across sites in the East Midland’s. We are committed to conducting business in accordance with all applicable laws and regulations in the UK, including the Act and health & safety, environmental, anti-bribery, equality and employment legislation. This extends to maintaining high standards of behaviour amongst our employees through our training and development initiatives.
We have established rigorous HR processes and controls to ensure that:

• All employees are assessed for their right to work in the UK
• Workplace equality policies and practices are in place, promoted and implemented
• Remuneration and benefit schemes comply with relevant UK employment legislation

We continually review and develop our policies, procedures and controls to ensure ethical and legal compliance.
We encourage our employees to report, in confidence, any concerns or breaches e.g., suspected unethical behaviour and wrongdoing. All matters raised either via whistleblowing, through direct communication with management or highlighted by our auditing processes are investigated, and appropriate action is taken in accordance with our policies and procedures.

Our Supply Chains

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or any part of our business. Further, we are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

We purchase and source products primarily from countries within the EU, including the UK. From the suppliers with whom we have direct purchasing relationships, we seek assurance during negotiations that they adhere to the same standards of corporate and ethical responsibility as we do ourselves.

Further steps

In developing our response to understanding and supporting the aims and requirements of the Act, going forward we will:

• Continue to raise awareness of our internal ‘Code of Conduct’ & ‘Anti-Slavery and Human Trafficking Policy’.
• Roll out a refresher Modern Slavery Act training module to all colleagues, with key colleagues undertaking an accredited training course.
• Continue to bring our standpoint and responsibilities to the fore in our communications with all stakeholders.
• Continue regular reporting cycle through our director and management team.
• Implement various measures to identify and mitigate risk and build on the approach deployed to ensure that we operate, as far as possible free from enforced labour, human trafficking and slavery.

Whilst we consider ourselves to be low risk given the vast bulk of our sourcing is from within the UK and EU, we will continue to review our processes and practices to ensure that we identify and manage risks to ensure our ongoing compliance with the Act.

Summary

This statement is made by 360 Commercial Cleaning Services Ltd (09183113).
This statement is made pursuant to section 54(1) of the Act and constitutes our slavery and trafficking statement for the financial year ending 31st March 2021.

Sarah Harrow
Managing Director – 360 Commercial Cleaning Services Ltd