Policy on Anti-Slavery, Human Trafficking and Human Rights

We want to be recognised as the UK’s leading sustainable business in the environmental services sector as part of the Reconomy Group which is the UK’s leading provider of outsourced waste management and recycling services. The company provides a tech-enabled, comprehensive waste and environmental management service through a nationwide network of approved service providers.

At ACM we aim to do the right thing for our customers, communities, investors, regulators and colleagues. We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and require our suppliers to do the same.

The following outlines our approach to prevent modern slavery and human trafficking and ensure human rights, the company will:

• Not tolerate or condone abuse of human rights anywhere in our business, our supply chain, or partnerships
• Take seriously any allegations that human rights are not properly respected in our business and our supply chain
• Issue an annual Anti-Slavery and Human Trafficking Statement
• Update and report on progress and actions taken to prevent modern slavery in our business and our supply chain
• Provide Anti-Slavery training for all key ACM staff particularity those involved in Supplier Management, Commercial and Compliance
• build our employees’ and suppliers’ awareness of human rights, encouraging them to speak up, without fear of retribution, about any concerns they may have
• Consult with the Charity Hope for Justice (0300 008 8000), if modern slavery was suspected, asking them for advice on the steps to take
• If Modern Slavery was identified, we have a clear escalation process. The senior Supplier Manager takes the lead supported by the Head of Sustainability and the Operations Director would be informed. We would refer to the Police and seek advice from the UK Gov modern slavery helpline 0800 0121 700 and the modern slavery helpline website and Hope for Justice ensuring that the victim(s) are placed at the centre of decision making
• Expect all suppliers to be compliant with the Modern Slavery Act 2015, and encourage them to make a statement irrespective of turnover
• Provide clear guidance on preventing modern slavery for our existing and new suppliers that is publicly available on our website
• Undertake a ‘heat map’ of preferred suppliers to understand the risk and focus efforts
• Make all suppliers aware of modern slavery risks at point of onboarding through our terms and conditions, code of practice and supplier guidance
• Ask suppliers to outline their approach to managing the risk of modern slavery
• Assess our preferred suppliers on site every 6 months
• Undertake Risk or Threat Assessments from customers as required
• Acm is committed to ensuring that there is no modern slavery or human trafficking in any part of our business and that human rights are upheld and require our suppliers to do the same.

Policy Holder: Travis Way, Managing Director

Date: 21 January 2021