1: Introduction

Policy Overview

Redcone Recruitment is fully committed to ensuring that all forms of modern slavery, human trafficking, and forced labour are eradicated from its operations, supply chain, and subcontracted services. This policy reaffirms Redcone Recruitment’s ethical commitment to preventing any form of modern slavery in line with the UK’s Modern Slavery Act 2015. It aligns with the standards outlined in our Ethical Policy, Environmental Policy, Quality of Product Policy, and applicable UK laws, ISO standards, and National Highways Sector Schemes (NHSS). By adopting a zero-tolerance approach, Redcone Recruitment ensures that all its practices, as well as those of its supply chain and

subcontractors, comply with legal and ethical labour standards.

1.2 Objective

The objective of this Modern Day Slavery Statement Policy is to detail Redcone Recruitment’s commitment to identifying, preventing, and addressing the risks of modern slavery in all areas of its operations, including the

provision of labour (NHSS 12A/B and 12D operatives) and subcontracted traffic management services. The policy outlines the steps taken to ensure that the company’s operations and business partners adhere to UK legal

requirements, ethical standards, and best practices.

2: Purpose

Key Anti-Slavery and Anti-Trafficking Objectives

This policy is designed to:

• Ensure that Redcone Recruitment complies with the Modern Slavery Act 2015 and all other relevant UK labour

• Protect human rights by preventing modern slavery and human trafficking in all its forms within the company’s operations and supply chain.

• Reinforce Redcone Recruitment’s Ethical Policy by ensuring ethical recruitment, treatment of employees, and responsible sourcing of materials.

• Ensure that all subcontractors and suppliers adhere to the highest ethical standards and respect human rights, including workers’ rights and working conditions.

• Promote transparency, accountability, and continuous improvement in preventing and addressing the risks of modern

3: Scope

Application of the Policy

This policy applies to all Redcone Recruitment employees, operatives, subcontractors, suppliers, and other business partners involved in the company’s traffic management operations. It governs recruitment practices, supply chain management, and subcontractor compliance in relation to human rights, ethical employment, and anti-slavery measures.

3.2 Legal Compliance

Redcone Recruitment will ensure compliance with all relevant UK laws and regulations, including:

• Modern Slavery Act 2015
• Human Rights Act 1998
• Employment Rights Act 1996
• Equality Act 2010
• Health and Safety at Work Act 1974
• ISO 9001: Quality Management
• ISO 45001: Occupational Health and Safety
• National Highways Sector Schemes (NHSS), particularly NHSS 12A/B and 12D for traffic management

4: Commitment to Preventing Modern Slavery and Human Trafficking

Zero-Tolerance Approach

Redcone Recruitment adopts a zero-tolerance approach to modern slavery, human trafficking, forced labour, and any form of exploitation within its operations and supply chain.

4.1.1 Prohibition of Forced Labour

Redcone Recruitment strictly prohibits the use of forced, bonded, or involuntary labour in any form. All employees and operatives are free to leave their employment after giving reasonable notice as required by law.

4.1.2 Prohibition of Child Labour

Redcone Recruitment is committed to ensuring that no individual under the legal minimum working age is employed, either directly by the company or within its supply chain and subcontracted services.

4.1.3 Protection from Human Trafficking

Redcone Recruitment will take all reasonable steps to ensure that no individuals employed or engaged in its operations have been subject to human trafficking, including working with external partners to verify labour rights protections throughout the supply chain.

4.2 Ethical Recruitment Practices

Redcone Recruitment will ensure that all recruitment practices comply with the highest ethical standards, including:

4.2.1 Transparent Hiring

All individuals employed by Redcone Recruitment, including NHSS 12A/B and 12D traffic management operatives, will be recruited through fair and transparent hiring processes. Workers will be provided with clear terms of employment, including pay, working hours, and other conditions.

4.2.2 Fair Wages

Redcone Recruitment is committed to paying all employees and subcontractors at least the UK’s minimum wage or the National Living Wage, where applicable. Wages will be paid regularly, and without delay, in accordance with legal requirements.

4.2.3 No Recruitment Fees

Redcone Recruitment will not charge employees any recruitment fees or other costs related to securing employment, in compliance with the Modern Slavery Act 2015 and international labour standards.

5: Subcontractor and Supply Chain Management

Supplier and Subcontractor Due Diligence

Redcone Recruitment recognises that the risks of modern slavery extend beyond its direct employees and into its supply chain and subcontracted services.

5.1.1 Supplier and Subcontractor Code of Conduct

All subcontractors and suppliers will be required to comply with Redcone Recruitment’s Supplier Code of Conduct, which includes strict anti-slavery provisions. This ensures that:

• They do not engage in or tolerate any form of modern slavery, human trafficking, or forced
• They provide safe working conditions, fair wages, and adhere to all relevant labour

5.1.2 Prequalification and Monitoring

Before engaging subcontractors or suppliers, Redcone Recruitment will conduct thorough due diligence to ensure compliance with ethical labour practices and modern slavery laws. This includes:

• Reviewing their policies and practices related to human rights and modern
• Conducting site visits and audits as necessary to assess their working conditions and labour
• Ensuring subcontractors and suppliers hold relevant certifications, such as ISO 9001 and ISO 45001, demonstrating their commitment to quality management and occupational health and safety.

5.1.3 Ongoing Compliance Monitoring

Redcone Recruitment will implement ongoing monitoring of its supply chain to ensure continued compliance with the Modern Slavery Act 2015. This includes regular reviews of suppliers’ and subcontractors’ practices and adherence to anti-slavery standards.

5.2 Termination of Contracts for Non-Compliance

Redcone Recruitment reserves the right to terminate relationships with any supplier or subcontractor found to be in breach of modern slavery laws or this policy.

6: Training and Awareness

EmployeeandSubcontractorTraining

Redcone Recruitment is committed to raising awareness of modern slavery risks and ensuring that all employees and subcontractors understand their role in preventing modern slavery.

6.1.1 Training Programmes

All employees and subcontractors will receive regular training on the following topics:

• The risks of modern slavery and human trafficking in the traffic management
• How to identify signs of modern slavery in the workplace and supply
• The importance of compliance with Redcone Recruitment’s anti-slavery policy and the Modern Slavery Act

6.1.2 Tailored Training for Managers

Managers and supervisors will receive additional training on how to handle concerns or suspicions related to modern slavery and how to conduct thorough due diligence when engaging suppliers or subcontractors.

6.2 Raising Awareness

Redcone Recruitment will implement ongoing initiatives to raise awareness among employees, subcontractors, and suppliers about modern slavery risks and responsibilities, including the provision of informational resources, posters, and regular updates on relevant legal developments.

7: Reporting Mechanisms and Whistleblowing

Reporting Suspected Modern Slavery

Redcone Recruitment encourages all employees, subcontractors, and stakeholders to report any concerns or suspicions regarding modern slavery or human trafficking.

7.1.1 Confidential Reporting Channels

A confidential whistleblowing mechanism will be available for employees to report suspected instances of modern slavery without fear of retaliation. Reports can be made anonymously, and the identity of whistleblowers will be protected.

7.1.2 Investigation of Reports

All reports of modern slavery or unethical practices will be thoroughly investigated by senior management. Where appropriate, Redcone Recruitment will cooperate with law enforcement agencies and regulatory bodies to ensure that perpetrators of modern slavery are prosecuted.

8: Continuous Improvement and Accountability

Ongoing Risk Assessments

Redcone Recruitment will regularly assess the risk of modern slavery in its operations and supply chain.

8.1.1 Risk Mitigation Strategies

Where risks are identified, Redcone Recruitment will take immediate steps to mitigate them. This may include enhancing supplier audits, improving worker welfare policies, or increasing scrutiny in high-risk areas of the supply chain.

8.1.2 Annual Modern Slavery Risk Review

Redcone Recruitment will conduct an annual review of modern slavery risks and the effectiveness of its policies and procedures in preventing exploitation. Any necessary policy updates or procedural changes will be implemented as a result of this review.

8.2 Accountability and Reporting

Redcone Recruitment’s board of directors will be responsible for overseeing the implementation of this Modern Day Slavery Statement Policy and ensuring its effectiveness.

8.2.1 Public Modern Slavery Statement

As required by the Modern Slavery Act 2015, Redcone Recruitment will publish an annual Modern Slavery Statement outlining the steps taken to prevent modern slavery and human trafficking in its business and supply chain. This statement will be publicly available on the company’s website.

9: Policy Review

Ongoing Review

This Modern Day Slavery Statement Policy will be reviewed annually, or in response to changes in legislation or significant changes in Redcone Recruitment’s operations.

9.2 Policy Updates

Any updates to this policy will be communicated to all employees, subcontractors, suppliers, and other stakeholders to ensure continued compliance and awareness of modern slavery risks.

10: Relevant Legal and Regulatory Considerations

Compliance with Legislation

This Modern Day Slavery Statement Policy has been developed in accordance with the following UK laws and regulations:

• Modern Slavery Act 2015
• Human Rights Act 1998
• Employment Rights Act 1996
• Equality Act 2010
• ISO 9001: Quality Management
• ISO 45001: Occupational Health and Safety
• National Highways Sector Schemes (NHSS), particularly NHSS 12A/B and 12D for traffic management

10.2 Commitment to Legal and Ethical Compliance

Redcone Recruitment is committed to ensuring that all its operations, supply chains, and subcontracted services are fully compliant with the Modern Slavery Act 2015 and aligned with the company’s ethical standards.

This Modern Day Slavery Statement Policy outlines Redcone Recruitment’s commitment to preventing modern slavery, human trafficking, and exploitation in all its business activities. By adhering to the principles of ethical recruitment, supplier due diligence, and continuous risk management, Redcone Recruitment aims to create a work environment and supply chain that respects human rights and upholds the highest standards of fairness, transparency, and responsibility.