Modern Slavery Policy 2026

MODERN SLAVERY AND
HUMAN TRAFFICKING POLICY

Robinson Landscapes Limited
Company No. 17145174

Policy owner

Director

Approved by

Director

Approval date

27 July 2026

Review date

27 July 2027, or earlier if legislation or business risks change

Version

1.0

Applies to

All directors, employees, workers, agency personnel, subcontractors, labour providers and suppliers

Status note: This is a voluntary company policy prepared for Robinson Landscapes Limited. Unless the company meets the statutory turnover threshold and other criteria in section 54 of the Modern Slavery Act 2015, it is not necessarily required to publish an annual statutory modern slavery statement. The company will reassess its legal reporting duties each financial year.

1. Policy statement

Robinson Landscapes Limited is committed to conducting business ethically, responsibly and with respect for human rights. We do not tolerate slavery, servitude, forced or compulsory labour, human trafficking, child labour, debt bondage, deceptive recruitment, withholding of identity documents, unlawful recruitment fees, or any other form of labour exploitation in our operations or supply chain.

We recognise that landscaping, construction and facilities-related supply chains can involve heightened risks because of subcontracting, temporary and migrant labour, labour shortages, low-margin work and complex purchasing arrangements. We therefore take proportionate, practical steps to prevent, identify, manage and address modern slavery risks.

No employee or worker will suffer retaliation for raising a concern in good faith. Where exploitation is suspected or identified, our priority is to protect affected people, preserve evidence, obtain specialist support and avoid actions that could increase harm.

2. Purpose and scope

This policy is intended to:

·    set the minimum standards expected throughout Robinson Landscapes Limited;

·    explain how modern slavery risks are assessed and managed;

·    provide clear reporting and escalation routes;

·    support responsible recruitment, procurement and site management; and

·    demonstrate our commitment to customers, employees and supply-chain partners.

The policy applies to all persons working for or on behalf of Robinson Landscapes Limited, including directors, employees, casual and agency workers, subcontractors, consultants, labour providers and suppliers. Compliance with this policy may form part of supplier selection, onboarding, contract terms and performance review.

3. Responsibilities

4. Recruitment and employment standards

·    We carry out proportionate right-to-work and identity checks before employment begins and retain records lawfully.

·    Workers must receive clear information about the role, pay, hours, deductions, location and key employment terms in a language and format they can understand.

·    No worker should pay unlawful or excessive recruitment fees to obtain work with us. Where a concern arises, it will be investigated and remedial action considered.

·    Workers retain control of their passports, identity documents, bank cards and personal belongings. Documents may be viewed or copied only for lawful checks and must be returned promptly.

·    Wages are paid lawfully and transparently. Deductions must be lawful, explained and recorded.

·    Workers are free to leave employment in accordance with their contractual terms and are not subjected to threats, intimidation, coercion or restriction of movement.

·    Where labour providers or agencies are used, we seek evidence that they are legitimate, properly managed and compliant with relevant legal and contractual requirements.

5. Supply-chain due diligence

Our due-diligence approach is proportionate to the nature, location and value of the goods or services supplied. It may include:

·    supplier pre-qualification questions covering modern slavery, ethical employment and labour sourcing;

·    confirmation of company identity, insurance, licences, accreditations and relevant policies;

·    review of how suppliers recruit, pay and manage workers, particularly where agency, migrant, temporary or subcontracted labour is used;

·    contract clauses requiring compliance with applicable modern slavery and employment law;

·    requests for supporting evidence, corrective-action plans or site visits where risk is higher;

·    monitoring of supplier performance, complaints, incidents and repeated warning signs; and

·    suspension or termination where a supplier refuses to cooperate or serious risks cannot be controlled, while considering potential harm to affected workers.

6. Risk indicators

Potential warning signs may include, but are not limited to:

7. Reporting concerns and responding

Anyone who suspects modern slavery, labour exploitation or unethical recruitment should report it immediately to their line manager or the Director. A concern may be raised verbally or in writing. Reports will be handled as sensitively as possible and information will be shared only where necessary.

When responding, Robinson Landscapes Limited will seek to:

·    consider any immediate danger and contact the emergency services where necessary;

·    avoid confronting a suspected exploiter where this could endanger workers or compromise an investigation;

·    record the concern factually and preserve relevant documents, messages, payment records or site information;

·    seek guidance from the police, the UK Modern Slavery Helpline, the Gangmasters and Labour Abuse Authority, or another appropriate specialist body;

·    protect the confidentiality and welfare of potential victims and avoid automatically removing work or income without considering the consequences;

·    cooperate with lawful investigations; and

·    review root causes and implement proportionate corrective and preventive action.

Deliberately false or malicious allegations may be dealt with under the appropriate disciplinary process. This does not apply to concerns raised honestly, even where they are not ultimately substantiated.

8. Training and awareness

Relevant employees, managers and supervisors will receive proportionate awareness training. This may cover definitions of modern slavery, warning signs, responsible recruitment, right-to-work processes, supplier due diligence, confidential reporting and safe escalation. Training completion and policy communication will be recorded where practicable.

9. Monitoring, records and continuous improvement

The Director will review implementation of this policy at least annually. Monitoring may include:

·    completion of relevant training and toolbox talks;

·    supplier policy and due-diligence checks;

·    labour-provider and right-to-work records;

·    reported concerns, investigations and corrective actions;

·    high-risk goods, materials, labour categories or geographic sources; and

·    lessons learned from incidents, customers, industry guidance and the Supply Chain Sustainability School.

Robinson Landscapes Limited will not claim that its business or supply chain is entirely 'slavery free'. Instead, we will be transparent about known risks and the practical steps taken to prevent and address them.

10. Breaches of this policy

A breach by an employee may result in disciplinary action, up to and including dismissal, subject to the applicable procedure. A breach by a supplier, subcontractor or labour provider may lead to additional monitoring, a corrective-action plan, suspension, removal from the approved-supplier list or termination of the relationship. Decisions will be proportionate and will consider the safety and welfare of affected workers.

11. Approval and review

This policy has been approved for implementation by Robinson Landscapes Limited. It will be reviewed annually, and sooner where there is a significant change in law, business activities, labour arrangements, supply-chain risk or customer requirements.

Signed

Mr James Robinson

Name

James Robinson

Position

Director

Date

27/07/2026