Anti-Slavery Policy

Introduction

This anti-slavery policy sets out the approach taken by TRM Innovations Ltd to preventing modern slavery, human trafficking, forced labour, bonded labour, child labour and exploitation within our business and supply chains.

TRM Innovations Ltd is a Bexleyheath-based building company providing services that may include extensions, refurbishments, kitchens, bathrooms, garage conversions, garden rooms, loft conversions and general building work.

We are committed to acting ethically and responsibly in all business dealings. We expect the same standards from employees, workers, subcontractors, suppliers, consultants and any other third party working with or on behalf of the company.

Purpose of This Policy

The purpose of this policy is to make clear that modern slavery and human trafficking are not acceptable in any part of our business.

This policy helps explain the standards expected from anyone connected to TRM Innovations Ltd and supports our commitment to fair, lawful and responsible working practices.

It also provides guidance on identifying and reporting concerns where exploitation, forced labour or unsafe working practices may be suspected.

Scope of This Policy

This policy applies to anyone working for or on behalf of TRM Innovations Ltd. This may include directors, employees, workers, subcontractors, suppliers, labourers, consultants, agency workers and other representatives.

It applies to all work-related activity, including quotations, project planning, building work, subcontractor arrangements, supplier relationships, site management, customer service and procurement.

Any person or organisation working with TRM Innovations Ltd is expected to avoid involvement in modern slavery, forced labour, exploitation or human trafficking.

What Modern Slavery Means

Modern slavery is a serious abuse of human rights. It may involve people being forced, controlled, threatened, deceived or exploited for labour, services or financial gain.

It can include forced labour, bonded labour, debt bondage, human trafficking, child exploitation, domestic servitude, withholding wages, restricting freedom of movement, threats, intimidation or using someone’s vulnerable position to exploit them.

Modern slavery can occur in many industries, including construction, labour supply, manufacturing, transport, cleaning, waste handling and materials supply.

Our Zero-Tolerance Position

TRM Innovations Ltd has a zero-tolerance approach to modern slavery, forced labour and human trafficking.

We will not knowingly work with any person or organisation involved in exploitation, unlawful labour practices, forced work, child labour, trafficking or serious abuse of workers.

Where a concern is identified, we will aim to review the matter and take appropriate action based on the circumstances.

Ethical Business Conduct

TRM Innovations Ltd expects business to be conducted honestly, fairly and responsibly.

Work should be carried out by people who are legally allowed to work, properly treated, paid as agreed and not subject to coercion, threats or exploitation.

We expect working relationships to be based on clear agreement, lawful conduct, safe working practice and respect for people’s rights.

Supplier and Subcontractor Standards

Suppliers and subcontractors play an important role in construction and home improvement work.

TRM Innovations Ltd expects suppliers, subcontractors and third parties to comply with applicable employment, labour, health and safety and anti-slavery laws.

We expect those working with us to avoid forced labour, unlawful wage practices, unsafe exploitation, human trafficking, debt bondage, illegal child labour and any conduct that abuses workers.

Labour and Recruitment Practices

TRM Innovations Ltd expects recruitment and labour arrangements to be lawful and fair.

Workers should not be charged improper recruitment fees, forced to surrender identity documents, threatened, misled about work, placed in debt bondage or made to work under coercion.

Anyone supplying labour to TRM Innovations Ltd should ensure that workers are legally entitled to work and understand the terms under which they are engaged.

Construction Industry Risks

The construction industry can involve complex supply chains, temporary labour, subcontracted trades, material suppliers and varying site arrangements.

These factors can create risk if labour is not properly managed or if suppliers do not follow lawful and ethical practices.

TRM Innovations Ltd aims to remain alert to signs of exploitation and expects subcontractors and suppliers to maintain proper standards.

Warning Signs of Modern Slavery

Possible warning signs may include workers appearing fearful, withdrawn, controlled or unable to speak freely.

Other signs may include a person not having control of their identity documents, being transported by someone who controls them, being unable to explain their work arrangements, appearing underpaid, living in poor conditions, working excessive hours or being accompanied by someone who speaks for them.

One sign alone may not prove exploitation, but concerns should not be ignored.

Forced Labour

Forced labour involves people being made to work against their will or under threat of punishment.

Threats may be physical, financial, emotional, immigration-related or linked to housing, debt, family pressure or loss of income.

TRM Innovations Ltd does not accept forced labour in any part of its work or supply chain.

Human Trafficking

Human trafficking involves arranging or facilitating the movement of people for the purpose of exploitation.

This may involve movement within the UK or across borders. It may include deception, coercion, control, threats, violence or abuse of vulnerability.

Any concern about trafficking should be treated seriously and reported through the appropriate route.

Child Labour

TRM Innovations Ltd does not support illegal child labour or exploitation of children.

Any person working on behalf of the company must be legally entitled to work and suitable for the duties being carried out.

Where young workers are lawfully engaged, they must be protected from unsafe, exploitative or unsuitable work.

Right to Work and Legal Compliance

People working for or on behalf of TRM Innovations Ltd should be legally entitled to carry out the work they are doing.

Where applicable, checks, agreements or evidence of legal working status may be required.

Suppliers and subcontractors are expected to comply with relevant legal requirements relating to labour, employment, tax, health and safety and worker welfare.

Working Conditions

TRM Innovations Ltd expects workers and subcontractors to be treated fairly and to work in safe and reasonable conditions.

Poor treatment, unsafe working environments, intimidation, withheld pay, excessive working hours, unlawful deductions or abusive behaviour are not acceptable.

Where concerns about working conditions arise, they should be reviewed and addressed appropriately.

Wages and Payment

Workers should be paid lawfully and in line with agreed arrangements.

TRM Innovations Ltd does not support practices such as withholding wages, making unlawful deductions, trapping workers through debt, charging improper recruitment fees or forcing people to work without proper payment.

Payment arrangements should be clear, fair and lawful.

Freedom of Movement

Workers should not be unlawfully restricted, controlled or prevented from leaving work.

No person should have their identity documents, bank cards, wages, phone or personal belongings withheld as a way of forcing labour or controlling behaviour.

Workers should be free to raise concerns and leave work arrangements in line with lawful and agreed terms.

Responsibilities

Everyone working for or on behalf of TRM Innovations Ltd has a responsibility to support this policy.

Workers and subcontractors should act lawfully, treat people fairly, report concerns and avoid working with anyone suspected of exploitation or trafficking.

Those arranging labour, materials, subcontractors or suppliers should remain alert to potential risks and take reasonable steps to avoid supporting unethical practices.

Reporting Concerns

Anyone who suspects modern slavery, forced labour, human trafficking or exploitation should report the concern as soon as possible.

Concerns may relate to a worker, supplier, subcontractor, customer site, labour provider or any third party connected to company activity.

Reports can be made using the contact details shown on this page. If someone is in immediate danger, emergency services should be contacted.

Handling Reports

TRM Innovations Ltd will aim to review any concern raised in good faith.

The response may depend on the nature of the concern, the people involved, the level of risk and whether outside authorities or specialist organisations need to be contacted.

The priority will be to protect people from harm and avoid supporting exploitative or unlawful practices.

Protection for Raising Concerns

TRM Innovations Ltd does not want anyone to ignore a genuine concern because they are worried about raising it.

Anyone who reports a concern honestly and in good faith should not be treated unfairly for doing so.

Deliberately false or malicious allegations may be treated differently, but genuine concerns should always be taken seriously.

Subcontractor and Supplier Review

Where a supplier, subcontractor or third party is suspected of involvement in modern slavery or exploitation, TRM Innovations Ltd may review the working relationship.

Depending on the circumstances, this may include asking for further information, pausing work, ending the relationship, refusing future work or reporting the matter to appropriate authorities.

We will not knowingly continue working with organisations that refuse to address serious concerns.

Training and Awareness

TRM Innovations Ltd aims to maintain awareness of modern slavery risks and the importance of ethical working practices.

Workers and subcontractors should understand that exploitation can happen in ordinary industries and may not always be obvious.

Where appropriate, the company may provide further guidance or reminders about identifying and reporting concerns.

Record Keeping

TRM Innovations Ltd may keep records relating to suppliers, subcontractors, labour arrangements, concerns raised and actions taken.

Good records can help support transparency and responsible decision-making.

Personal information will be handled carefully and in line with relevant privacy requirements.

Continuous Improvement

TRM Innovations Ltd recognises that preventing modern slavery is an ongoing responsibility.

We aim to review our working practices, supplier relationships and subcontractor arrangements where needed.

Practical improvements may include clearer expectations, better communication, stronger checks and greater awareness of risks within construction and related supply chains.

Relationship With Other Policies

This anti-slavery policy should be read alongside other relevant company policies, including the Anti-Bribery Policy, Health and Safety Policy, Equal Opportunities Policy, Discrimination Policy, Safeguarding Policy and Complaints Policy.

Together, these policies support ethical, safe and responsible business conduct.

Policy Review

This anti-slavery policy may be reviewed and updated from time to time to reflect changes in working practices, legal requirements, supplier arrangements or company procedures.

Any updates will be published on this page.

Contact Details

If you have any questions about this anti-slavery policy or wish to raise a concern, you can contact TRM Innovations Ltd using the contact details shown on this page.

This anti-slavery policy was last updated in June 2026.