Statement of Intent

For the purposes of this Modern Slavery Act 2015 policy the term “Company” refers to the following:

Stanton & Partners Limited

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking policy for the Company’s operations.

Our policies on slavery and human trafficking:

The Company is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  

To ensure that all parts of our business and supplier network are slavery free we have put in place a policy on Slavery and Human Trafficking which demonstrates our commitment 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 company or supplier network.

The Board of Directors has reviewed the risk of modern slavery within the Company and maintains the risk to be low. This assessment is based upon the nature of the business, which is a service, based in and operating almost exclusively within Greater London, UK. 

The Group’s standard practice is to check that prospective employees have the right to work in the UK. We do not generally employ agency staff. Where we work with suppliers, these are generally larger organisations.

We are committed to conducting our business with honesty and integrity. We adopt and promote a culture of honesty and integrity. 

We operate a whistle blowing policy, of which all employees are aware, and which encourages staff to report illegal activities, suspected wrong-doing or malpractice, including suspected slavery or trafficking as soon as possible.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk we have in place:

Human Resource procedures

A comprehensive range of policies and practices have been applied including an Equal Opportunities Policy along with a formal grievance and disciplinary policy to protect and ensure that staff rights and responsibilities are upheld.

The Company pays hourly rates equivalent to or above the National Minimum Wage rates.

Procurement procedures

We vet parties who want to work with us and expect them to adhere to our policy and principles. We are committed to ensuring that there is no slavery or human trafficking in our organisation or our supply chain. 

Incorporate within the tender process to address slavery and human trafficking with potential new suppliers.

Supplier adherence to our values

The Company has a zero tolerance to slavery and human trafficking. To ensure all those in our supply chain (including contractors) network comply with our values we have in place a supply chain compliance action list.

Engage with our supplier base to secure a commitment to work with the Company to identify and monitor slavery and human trafficking down the supply chain.

Register all supplier responses on an annual basis.

Engage with potential new suppliers about commitment to the Company’s Anti-Slavery and Human Trafficking Policy.

Due diligence

We consider modern slavery not only in terms of our supply chain, but alongside other appropriate policies – most notably our Anti-Money Laundering Policy, as part of which all relevant staff are trained. We identify the possible risks of modern slavery and human trafficking within the private rented sector, for example, illegal immigration or prostitution. Where we identify such wrongdoing, we will not hesitate to notify and co- operate with the authorities to ensure that victims are helped, and that perpetrators are pursued. 

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 our staff.

Further steps

We continue to build on our policy by reviewing and reinforcing the steps we take to vet both existing and new suppliers, adopting a risk-based approach, to reduce as far as possible the risk of slavery and human trafficking anywhere in our supply chains.

In addition, we will ensure that all of our staff understand the risks of modern slavery and human trafficking to our business and supply chains and that they are aware that such practices will not be tolerated.

This policy has been endorsed by the directors and has the full support of the management.

The policy was approved on 1st April 2025 following consultation with senior managers, workers, and workers’ representatives.

Overall responsibility for the effectiveness of the policy lies with the directors.