Anti-Slavery / Human Rights Policy

Anti-Slavery / Human Rights Policy

As a Company, Aspire Industrial Services Ltd maintains relationships with many different organisations in its supply chain, as well as employing directly. In the light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have determined the measures that may be required to prevent slavery and human trafficking taking place in any part of our businesses or in our supply chains.
The Company has implemented a statement of our corporate values on the prevention of modern slavery and human trafficking. The value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.
We expect all who have, or seek to have, a business relationship with Aspire Industrial Services Ltd and/or any member of our Company, to familiarise themselves with our antislavery value and to act at all times in a way which is consistent with our antislavery value.

AntiSlavery Value

As part of our culture of governance for good business, we operate to a set of core values which reflect our relationships including customers, manufacturers, shareholders, suppliers and team members. We adopt a behavioural value for all our business relationships, reflecting our attitude to the exploitation of individuals in any form, and more particularly the offences under the Modern Slavery Act 2015. We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings. Our attitude to modern slavery is: zero tolerance.

1. Purpose of this Policy

1.1 Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This document sets out the policy of Aspire Industrial Services Ltd (the “Company”) with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.

1.2 As a Company, we have a zerotolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own businesses or those of our suppliers.

2. Steps for the Prevention of Modern Slavery

2.1 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children we expect our suppliers to hold their own suppliers to the same high standards.

2.2 All team members have an obligation to familiarise themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented. Adherence to this policy forms part of all team members’ obligations under their contract of

2.3 Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human  trafficking is not taking place in our supply chains, we
acknowledge that we do not control the conduct of individuals and organisations in our supply chains. To underpin our compliance with practical steps, we intend to implement the following measure:

conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas;

engage with our suppliers both to convey to them our AntiSlavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their  businesses;

where appropriate, as informed by our risk assessment, seek to introduce supplier prescreening (for example as part of our tender process) and selfreporting for our suppliers on safeguarding controls;

introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.

3. Responsibility for the Policy

3.1 Ultimate responsibility for the prevention of modern slavery rests with the Company’s leadership. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

3.2 Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

4. Actions to Report Modern Slavery or Human Trafficking
You should contact a member of the management team in any of the following circumstances:

You suspect a person acting on behalf of Aspire or one of our businesses is seeking to exploit another in a way which could amount to modern slavery;

You suspect that a person acting on behalf of one of our suppliers is seeking to exploit another in a way which could amount to modern slavery;

You have received an approach from a person acting on behalf of Aspire or one of our suppliers who has invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed;

You have information which leads to the rational conclusion that a person acting on behalf of Aspire or one of our suppliers is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015 Reports are kept in confidence, subject to the need for the company to act responsibly and within the law. Reports will be kept confidential unless the report made is not consistent with the maintaining of our procedures for the prevention of modern slavery being committed on our behalf or in any element of our supply chain.

5. Safeguards

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

The Company will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

6. Communication and Awareness of this Policy

Our zerotolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

7. Review

Following its initial adoption, this AntiSlavery and Human Trafficking Policy will be reviewed by the Company Directors and the Human Resources Department on a regular basis (annually) and may be amended from time to time.


C. Donnelly

14th December 2020

Claire Donnelly

Managing Director (Review December 2021)