C WRAY LTD – MODERN SLAVERY & HUMAN TRAFFICKING POLICY

Effective Date: 01/04/2026
Version: 1.0

C Wray Ltd is committed to preventing modern slavery and human trafficking in all aspects of our business and supply chain. We operate with integrity and transparency and fully support the principles of the Modern Slavery Act 2015.

This policy applies to all employees, directors, operatives, subcontractors, and third parties engaged by or working with C Wray Ltd.

Our Position

C Wray Ltd has a zero-tolerance approach to modern slavery, including:

  • Forced or compulsory labour

  • Human trafficking

  • Debt bondage

  • Exploitative working conditions

  • Withholding of wages or identification documents

We are committed to ensuring that all workers are treated fairly, paid appropriately, and engaged voluntarily.

Our Business Model & Risk Awareness

As a labour supply agency operating within the construction sector, we recognise that risks may arise in:

  • Recruitment and onboarding of workers

  • Use of subcontractors or labour-only operatives

  • Supply chains linked to construction and maintenance services

We actively manage these risks through strict vetting and compliance procedures.

Due Diligence & Controls

C Wray Ltd will:

  • Verify the identity and right to work of all operatives

  • Ensure all workers are engaged voluntarily and understand their terms of work

  • Check qualifications and background information where applicable

  • Avoid working with individuals or organisations that cannot demonstrate ethical practices

  • Maintain clear and transparent payment processes

Fair Treatment of Workers

We are committed to:

  • Paying workers fairly and on time

  • Ensuring safe working conditions in line with site requirements

  • Respecting workers’ rights and freedom of movement

  • Preventing any form of coercion, intimidation, or exploitation

Reporting Concerns

All individuals associated with C Wray Ltd are encouraged to report any concerns relating to modern slavery or unethical practices.

Reports will be:

  • Treated confidentially

  • Investigated promptly

  • Addressed without retaliation against the person raising the concern

Continuous Improvement

C Wray Ltd will:

  • Regularly review its recruitment and onboarding processes

  • Monitor risks within its workforce and supply chain

  • Promote awareness of modern slavery risks within the business

Breaches

Any breach of this policy may result in:

  • Termination of contracts or working relationships

  • Removal from the company’s database

  • Reporting to relevant authorities where necessary

Responsibility

The Director of C Wray Ltd is responsible for implementing and reviewing this policy to ensure it remains effective and relevant.

Signed:
 Jovid Cain
Director, C Wray Ltd