Protecting Workers and Ethical Labour Supply
Version: 1.0 · Published: 21 October 2026 · Policy responsibility: UK Operations, with director oversight · Review: by 21 October 2027, or sooner following a relevant change.
Purpose and scope
Citywide Services LTD, trading as Citywide Cleaning Company, must not tolerate forced labour, human trafficking, coercive recruitment or exploitation within its operations or labour supply. This policy sets requirements for identifying risk, raising concerns and responding in a way that protects affected people.
It applies to direct recruitment, agency labour, subcontract cleaning arrangements and relevant purchasing. Suppliers and labour providers must be informed of the requirements relevant to their work. A signed declaration is one piece of evidence, not proof that exploitation is absent.
What exploitation can look like
Modern slavery can involve threats, coercion, deception, debt or abuse of vulnerability that prevents a person making free choices about their work. Risk can occur in ordinary-looking workplaces. A person’s nationality, shared accommodation or use of transport supplied by someone else is not, by itself, evidence of exploitation.
Cleaning can involve fragmented labour chains, isolated working and cost pressure. Assessment should focus on the combination of indicators, what workers say safely and the evidence available, rather than stereotypes or unsupported accusations.
Responsibilities and employment principles
A director must oversee serious concerns and the response to them. UK Operations must assess labour-provider risks, communicate expectations, maintain factual records and track corrective action. Managers must offer workers a route to raise concerns without requiring them to confront a suspected exploiter. Workers and suppliers must report reasonable concerns and cooperate with lawful enquiries.
The following requirements apply:
- Recruitment for Citywide work must not rely on worker-paid job-placement fees. Where fees or related debt are identified, escalate them for assessment and remedy rather than ignoring them because an intermediary collected them.
- No person may retain identity documents coercively, prevent lawful access to them or restrict a worker’s lawful freedom to leave employment.
- Pay, hours, deductions and work expectations must be explained in understandable terms. Pay and deductions must meet applicable legal requirements.
- No threats, violence, intimidation, deceptive job offers or retaliation against people raising reasonable concerns are acceptable.
- Transport or accommodation arrangements must not be used to control workers or conceal abusive charges.
- Employment status must reflect the real arrangement; contractual labels must not be used to avoid legal obligations.
These are policy requirements, not a claim that an audit has verified every supplier or that no incident has ever occurred.
Risk-based labour-provider checks
Before appointment, the responsible manager must identify the supplying business, its role in the labour chain and any permitted further subcontracting. Review the recruitment model, fee arrangements, wage and deduction controls, checking responsibilities and the ability of workers to raise concerns directly.
Higher-risk arrangements require more detailed enquiry. Relevant triggers include unexplained substitutions, reluctance to identify the employer, inconsistent payroll information, apparent worker-paid fees and pricing that appears incompatible with the resources required. A low quotation alone is not proof of exploitation, but may justify a cost explanation.
Monitoring must include opportunities for workers to speak without a supplier or supervisor controlling the conversation. Do not assume that a completed questionnaire or zero complaints establishes the absence of risk.
Indicators and appropriate first action
| Indicator | What to do |
|---|---|
| A worker says they paid a large fee to obtain work | Listen privately, record the facts and escalate possible debt-related coercion |
| A third party controls a passport or wages | Assess safety and seek appropriate specialist advice; avoid an unsafe confrontation |
| A worker appears frightened to speak or cannot describe their employer | Arrange a safe conversation without treating fear as proof of a crime |
| A substitute arrives through an unclear labour chain | Verify identity, authorisation and supplier responsibility before deployment |
| Unexplained deductions or threats linked to accommodation or transport | Preserve factual information safely and assess the combined indicators |
Illustrative example: An agency cleaner says they owe money to the person who arranged their job and transport. The manager should not immediately telephone that person in front of the worker. First establish a safe way to communicate, assess immediate risk and seek appropriate support.
Reporting safely
Workers may raise a concern with a supervisor, UK Operations or request director-level review through Contact Citywide. If an internal manager is implicated, use a route that bypasses that person. The company contact route is not an emergency service and does not promise round-the-clock monitoring.
For immediate danger, contact the emergency services on 999. For non-emergency police reporting, use 101. A person may also seek independent specialist support through the current routes listed in the government’s modern slavery guidance. No worker is required to investigate suspected criminal activity.
Reports must be treated sensitively and shared only as necessary for safety, assessment, legal obligations and appropriate action. Absolute confidentiality cannot be promised where information must be disclosed. Reasonable concerns must not result in retaliation; deliberately malicious allegations are a separate matter requiring fair assessment.
Response, remedy and follow-up
- Assess immediate safety and urgent support needs.
- Listen without pressuring the person to repeat unnecessary details; establish a safe contact method.
- Record factual information, distinguishing observation, allegation and confirmed findings.
- Escalate to an appropriate senior person and seek specialist or police advice where indicated.
- Consider lawful, worker-centred remedies, including fees, deductions, documents, pay or safe working arrangements where relevant.
- Decide proportionate supplier action and monitor the outcome.
Automatic supplier termination can worsen a worker’s situation. Immediate protective action may be essential, but decisions should consider the person’s safety, available remedy and any ongoing investigation. Managers must not promise a particular immigration, criminal justice or compensation outcome.
Monitoring, privacy and statutory reporting
UK Operations must maintain a proportionate risk register, supplier review records, concern logs, action owners and follow-up outcomes. Restrict access to sensitive personal information. Management review should consider labour-chain visibility, overdue corrective actions and whether workers can raise concerns safely. Zero reports are not evidence of zero exploitation.
This is an ongoing policy, not a financial-year statement under section 54 of the Modern Slavery Act 2015. A director must assess whether the business meets the statutory reporting criteria, including the applicable turnover test and other conditions. If reporting is required, a separate statement must accurately describe actions during the relevant financial year and meet approval, signature and publication requirements. This policy does not claim that Citywide is either required to report or exempt.
Related policies and reference basis
Read alongside the Recruitment and Vetting and Staff Training and Competence policies, and the existing Citywide policies. These expectations apply to labour supporting London office cleaning and wider UK cleaning operations; local site requirements do not override worker protection.
References: Home Office transparency guidance and government procurement guidance on modern slavery risk. Procurement guidance is a useful benchmark and is not automatically a duty imposed on every private contract.
