Modern Slavery Policy

1. Introduction:

Airborne Property Services Ltd is committed to preventing modern slavery and human trafficking in all its business activities and ensuring that its supply chains are free from such practices.

2. Purpose:

The purpose of this policy is to outline our commitment to combating modern slavery and the steps we have taken and will continue to take, in line with Section 54 of the Modern Slavery Act 2015.

3. Organizational Structure:

APS Ltd is a principal contractor that uses a top-down business structure to monitor, perform, and audit its activities. Alistair Harriss, the managing director, maintains strict oversight of all subcontractors and employees. If any form of modern slavery or human trafficking is observed, the company adopts a “tools down” approach—immediately stopping work and reporting the incident to the authorities without delay.

4. Our Policies:

We uphold several policies and practices to mitigate the risk of modern slavery:

Code of Conduct: Our Code of Conduct sets out the behaviours and ethical principles expected of all employees and suppliers.

Whistleblower Policy: We provide a safe and confidential reporting mechanism for unethical practices, including modern slavery.

Supplier Code of Conduct: Outlining our expectations regarding supply chain protocols.

5. Due Diligence:

We perform due diligence when considering new suppliers and regularly review existing ones. This includes:

Evaluating the risks of modern slavery through supplier assessments.

Conducting audits and on-site inspections.

Requiring all suppliers to confirm adherence to our anti-slavery policy.

6. Risk Assessment:

An annual risk assessment is conducted to identify areas of high risk within our operations and supply chains. We focus on:

Countries with a high risk of modern slavery.

Industries prone to exploitation.

7. Training and Awareness:

We provide training to ensure our employees are aware of modern slavery issues and can effectively identify and report potential cases.

8. Monitoring and Reporting:

We monitor compliance with this policy through a combination of audits, self-assessments, and spot checks. Non-compliance will be addressed promptly, with measures including termination of contracts.

9. Continuous Improvement:

We are committed to continuously improving our practices and procedures to combat modern slavery and adapting our approach as necessary.

10. Approval and Review:

This policy has been approved by [Relevant Senior Management/Owner Name] and is reviewed annually to ensure continued relevance and effectiveness.

11. Contact Information:

For any questions or to report concerns regarding our Modern Slavery Policy, please contact Alistair Harriss at ali@airbornepropertyservices.com