Copdock Mill Modern Slavery Policy

A) ORGANISATION

This Modern Slavery Statement applies to H.G. Gladwell & Sons Limited (hereafter ‘the Organisation’). It covers the financial year ending 31 March 2025.

B) ORGANISATIONAL STRUCTURE

The Organisation operates from its Head Office in Copdock, Suffolk, with branches primarily across the South East of England. It is governed by a Board of Directors based at the Head Office.

C) DEFINITIONS

The Organisation considers modern slavery to include, but is not limited to:
– Human trafficking
– Forced or compulsory labour, including through mental or physical threat
– Situations where individuals are owned or controlled by an employer through abuse or threats
– Dehumanisation and treatment as a commodity
– Restriction of freedom of movement or physical confinement

D) COMMITMENT

The Organisation acknowledges its responsibility to prevent modern slavery and human trafficking and is committed to ensuring transparency within its operations and supply chains in accordance with the Modern Slavery Act 2015. We regularly review internal policies and supply chain practices to maintain compliance.

E) SUPPLY CHAINS

The Organisation’s primary supply chains are based in the United Kingdom, with limited involvement from suppliers within the European Union.

F) POTENTIAL EXPOSURE

The Organisation considers its risk of exposure to modern slavery and human trafficking to be low, due to its limited reliance on supply chains outside the UK and the EU. Nevertheless, the Organisation remains vigilant and takes reasonable steps to ensure that such risks are identified and mitigated.

G) STEPS

The Organisation undertakes due diligence to identify and mitigate the risk of modern slavery. This includes:
– Reviewing suppliers’ compliance with the Modern Slavery Act
– Requesting and reviewing Modern Slavery Statements where applicable
– Conducting supplier risk assessments when necessary

H) KEY PERFORMANCE INDICATORS

The Organisation has set key performance indicators (KPIs) to measure its effectiveness in preventing modern slavery, including:
– Percentage of new suppliers vetted for modern slavery risks
– Number of suppliers with up-to-date Modern Slavery Statements
– Number of staff trained annually on modern slavery awareness
If a new supplier is to be engaged, controlled outside the UK or the European Union, the Board must be advised before any contract is entered into to allow the Board to conduct due diligence on the potential supplier.

I) POLICIES

The Organisation maintains strict policies regarding supplier engagement, including:
– No contracts may be entered into with suppliers based or controlled outside the UK or EU without prior written approval from the Board
– Such approval must be formally recorded in Board minutes and stored in the Organisation’s CRM system under the relevant supplier profile

J) TRAINING

Purchasing staff have been made aware of the Organisation’s modern slavery policy. Ongoing awareness and refresher training are reviewed annually to ensure continued compliance.

K) SLAVERY COMPLIANCE OFFICER

While the Organisation does not currently have a designated Slavery Compliance Officer, all concerns or suspicions relating to modern slavery must be reported directly to the Board. The Board assumes joint responsibility for investigating and taking appropriate action.

This statement is made under Section 54 (1) of the Modern Slavery Act 2015 and will be reviewed annually.

Approved by the Board of Directors on 1st April 2025.

Signed: SJ Gladwell
Simon Gladwell
Managing Director
H.G. Gladwell & Sons Limited