# MODERN SLAVERY AND ANTI-HUMAN TRAFFICKING POLICY
Date: 1 February 2033
Parties: Northbridge Civils plc, its workforce and supply chain
## 1. Purpose and parties
Northbridge Civils plc, company number 06311429, approves this policy on 1 February 2033 for its England and Wales operations and controlled suppliers. Chief Executive Aisha Khan is the board sponsor, and Procurement Director Ben Morris is responsible for implementation. Global turnover for the year ended 31 December 2032 was £42,600,000, so the board will publish a Modern Slavery Act 2015 section 54 statement with this policy's actions and measures.
## 2. Facts, scope and terms
The company has zero tolerance for slavery, servitude, forced or compulsory labour, debt bondage, child labour and human trafficking. The initial risk review rated temporary labour in construction, overseas stone, cleaning and security as medium or high risk because of recruitment fees, migrant work and subcontracting. Indicators include withheld identity documents, restricted movement, threats, unexplained deductions, excessive hours, unpaid wages and workers unable to leave freely.
## 3. Process and responsibilities
Before appointment, every new supplier must complete the 18-question labour-practices questionnaire, identify its subcontractors, name a responsible manager and confirm compliance with applicable law. Contracts require no worker-paid recruitment fee, lawful pay and hours, access to identity documents, flow-down obligations and a right to audit on 10 working days' notice. Red suppliers are audited annually, amber suppliers every two years and green suppliers every three years.
## 4. Evidence, records and safeguards
Northbridge will train all 214 staff by 31 March 2033, with enhanced training for procurement, site supervisors and those arranging labour. A supplier review on 20 January 2033 found that Redstone Labour Hire Ltd had not evidenced recruitment-fee controls; Northbridge placed it on a corrective-action plan due by 17 February 2033 and will suspend new placements if evidence is not supplied. Remediation prioritises worker safety and repayment rather than concealing a problem.
## 5. Review, escalation and outcome
Anyone may report to Compliance Officer Laura Evans at speakup@northbridge.example or 029 5550 1842, anonymously if preferred. A concern suggesting immediate danger should go to 999; potential victims may be referred through the National Referral Mechanism by police, the Gangmasters and Labour Abuse Authority or another competent first responder. The Modern Slavery Helpline is 08000 121 700 and the GLAA helpline is 0800 432 0804.
## 6. Reservations and practical protections
Reports are handled confidentially, shared only on a need-to-know basis and protected from retaliation; a qualifying protected disclosure will be treated consistently with the Employment Rights Act 1996. The safeguarding lead will arrange a safe conversation, interpreter, independent advice and urgent accommodation or medical help where appropriate. Records will document consent, risk, referrals and outcomes without requiring a potential victim to prove the allegation before support is offered.
## 7. England and Wales law and completion
This completed fictional policy is governed by England and Wales law and will be reviewed by the board on 1 February 2034. Northbridge will publish its annual statement, measure training completion, audits, corrective actions and worker remedies, and report serious crime to the police or National Crime Agency. No supplier contract, confidentiality term or commercial deadline prevents lawful reporting, victim protection or compliance with the Modern Slavery Act 2015.