SMARTWAY Traffic Management is committed to acting ethically, transparently and with integrity across our business and supply chain.
Document Ref STM-POL-005
Company SMARTWAY Traffic Management
Issue Date April 2026
Next Review April 2027
Approved By John E Whelan — Managing Director
Address Rye Common Lane, Farnham, GU10 5DD
Legal Framework
This policy is underpinned by the Modern Slavery Act 2015 and applies to all employees, subcontractors, labour providers and supply chain partners.
Our Commitments
- We will not knowingly use suppliers, subcontractors or labour providers that engage in or tolerate modern slavery.
- We carry out appropriate checks on suppliers and subcontractors.
- All workers must be free to leave their employment and must not be subject to forced labour, coercion or duress.
- We provide awareness to staff on recognising and reporting signs of modern slavery.
Training, Awareness & Due Diligence
We expect employees, subcontractors and suppliers to act ethically and report any concerns. Where required, supplier and subcontractor checks are reviewed as part of our management procedures.
Reporting Concerns
Anyone who suspects modern slavery is occurring within our business or supply chain must report this immediately to the Managing Director. Reports can be made confidentially. SMARTWAY Traffic Management will cooperate fully with law enforcement and relevant authorities where required.
Anti-Bribery & Corruption
SMARTWAY Traffic Management operates a zero-tolerance policy towards bribery and corruption. We comply with the Bribery Act 2010 and will not engage in, facilitate or encourage bribery or corrupt practice.
- Cash or cash-equivalent payments are never acceptable.
- Gifts or hospitality must not be used to improperly influence business decisions.
- Any suspected bribery or corruption must be reported to the Managing Director.
Related Documents
- STM-PROC-004 — Training & Competency Procedure
- STM-PROC-006 — Non-Conformance & Corrective Action Procedure
- STM-PROC-008 — Subcontractor Management Procedure
- STM-REG-002 — Approved Supplier / Subcontractor Register
Legal Framework
This policy is underpinned by the Modern Slavery Act 2015 and applies to all employees, subcontractors, labour providers and supply chain partners.
Our Commitments
- We will not knowingly use suppliers, subcontractors or labour providers that engage in or tolerate modern slavery.
- We carry out appropriate checks on suppliers and subcontractors.
- All workers must be free to leave their employment and must not be subject to forced labour, coercion or duress.
- We provide awareness to staff on recognising and reporting signs of modern slavery.
Training, Awareness & Due Diligence
We expect employees, subcontractors and suppliers to act ethically and report any concerns. Where required, supplier and subcontractor checks are reviewed as part of our management procedures.
Reporting Concerns
Anyone who suspects modern slavery is occurring within our business or supply chain must report this immediately to the Managing Director. Reports can be made confidentially. SMARTWAY Traffic Management will cooperate fully with law enforcement and relevant authorities where required.
Anti-Bribery & Corruption
SMARTWAY Traffic Management operates a zero-tolerance policy towards bribery and corruption. We comply with the Bribery Act 2010 and will not engage in, facilitate or encourage bribery or corrupt practice.
- Cash or cash-equivalent payments are never acceptable.
- Gifts or hospitality must not be used to improperly influence business decisions.
- Any suspected bribery or corruption must be reported to the Managing Director.
Related Documents
STM-REG-002 — Approved Supplier / Subcontractor Register
STM-PROC-004 — Training & Competency Procedure
STM-PROC-006 — Non-Conformance & Corrective Action Procedure
STM-PROC-008 — Subcontractor Management Procedure