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Modern Slavery & Human Trafficking Policy

Modern Slavery & Human Trafficking Policy

SMARTWAY Traffic Management is committed to acting ethically, transparently and with integrity across our business and supply chain.

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-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
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