Modern Slavery Policy

MODERN SLAVERY POLICY/ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY

1. Policy Statement:

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. Servicemaster Clean by Deeland has a zero-tolerance approach to modern slavery and 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 business or in any of our supply chains.

1.2 We are also 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 as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

1.3 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

2.Organisational Structure:

2.1 We are a UK based limited company formed in April 1998. We also operate as an Employee-Owned Trust.  Our principal business address is 101 Mill Lane, Newbury, RG14 5RE. We trade under the name ServiceMaster Clean by Deeland.

3.Responsibility for the Policy

3.1 The Business Services Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

3.2 The Senior Management Team has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

3.3 Managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are aware of the issue of modern slavery in supply chains.

4.Compliance with the Policy

4.1 All staff must read, understand and comply with this policy.

4.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. All staff are required to avoid any activity that might lead to, or suggest, a breach of this policy.

4.3  All staff must notify their manager in confidence as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.

4.4 All staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

4.5 If they believe or suspect a breach of this policy has occurred or that it may occur they must notify their manager, a member of the Senior Management and/or Human Resources as soon as possible in confidence.

4.6 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. If anyone believes that they have suffered any such treatment, they should inform their manager and/or Human Resources immediately. If the matter is not remedied, and they are an employee, they should raise it formally using our Grievance Procedure.

4.7 To ensure that our suppliers comply with our values we engage with them to commit to working with us to identify and monitor slavery and human trafficking throughout the supply chain. 

4.8 To facilitate this there are a range of policies and practices in place including an Equality, Inclusion and Diversity Policy, Grievance Procedures and Disciplinary Procedures to ensure that staff rights and responsibilities are upheld.

4.9 The company also pays hourly rates equivalent or above the National Minimum Wage.

5.Communication and awareness of this policy

5.1 Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us.

5.2 We intend to include Modern Slavery as a regular agenda item at our Senior Management Meetings.

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

6.Compliance within Procurement

 6.1 We incorporate safeguards within the tender process to address slavery and human trafficking with potential new suppliers.

6.2 All supplier responses are registered as part of the onboarding process, and we expect all suppliers to commit to the company’s anti-slavery and human trafficking policy.

 7.Breaches of this policy

 7.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

7.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Reviewed February 2026

Jane Paisley

Business Services Director                                                                                                  12.02.2026

Appendix 1:  Guidance on how to spot the signs of modern slavery

Below is a list of some of the more common signs of modern slavery:

Physical and psychological abuse: Many victims will look malnourished and may appear withdrawn when you try to communicate with them. Signs of physical abuse could be apparent, such as bruising and other injuries.

Restricted movement: Victims may not be allowed to travel alone and will not be in possession of their passport. They may seem under the influence of others, have little interaction, and be unfamiliar with the surroundings in which they are working.

Poor accommodation: A victim of modern slavery will likely have an extremely poor standard of living, often staying on site in cramped and dirty conditions with other workers. It is also quite possible that they would not know their home or work address.

Lack of personal belongings: As well as having no form of identification, such as a passport, a victim of modern slavery will likely have very few personal possessions and wear the same clothes every day. These clothes could appear unsuitable for their working conditions.

Unusual behaviour: It is quite common for victims of modern slavery to avoid eye contact, continually appear frightened, and allow others to speak for them when addressed directly. They will be very reluctant to ask for help, quite possibly due to fear of further abuse or fear of deportation.