AJF | Policy owner: Director
1 Policy statement and scope
AJF is committed to conducting business ethically and respecting human rights. We prohibit modern slavery and human trafficking and will take proportionate steps to prevent, identify and address exploitation in our operations and supply chains.
This policy applies to the Director, all employees, temporary and agency workers, and anyone acting for or on behalf of AJF, in the UK and overseas. AJF expects suppliers, subcontractors, recruitment agencies and other business partners to meet equivalent standards.
AJF will comply with applicable anti-slavery and human trafficking law, including the Modern Slavery Act 2015 and relevant legislation in Scotland, Northern Ireland and other countries where it operates.
2 What modern slavery means
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. It involves exploitation of people through coercion, threats, deception, abuse of vulnerability or other forms of control. A person may be exploited even if they initially agreed to the work or travelled voluntarily. Human trafficking does not require crossing an international border.
AJF prohibits forced labour, debt bondage, trafficking and child labour that is unlawful or exploitative. No one may knowingly facilitate exploitation through AJF’s recruitment, transport services, purchasing or other business activities.
3 Employment and recruitment standards
Work must be freely chosen. Workers must be free to leave employment on lawful and reasonable notice, without threats, unlawful penalties or coercion. They must be free to leave the workplace when not required to be there under lawful working arrangements.
AJF will verify identity, age and entitlement to work as legally required, provide clear written employment terms, and comply with applicable wage, working time, rest and health and safety requirements. Wages must be paid to the worker through a legitimate arrangement, with transparent and lawful deductions.
Workers must not be charged recruitment fees or related costs to obtain work for AJF, whether directly or through an intermediary. AJF will require recruitment providers to meet this standard and will address identified breaches, including seeking repayment of improper charges.
AJF will not retain original identity documents, passports or immigration papers to restrict a worker’s freedom. Documents needed for lawful checks must be returned promptly. No deposits, debts or accommodation arrangements may be used to trap people in work.
4 Suppliers and business partners
AJF will assess modern slavery risks proportionately when selecting and reviewing suppliers and other partners. For a forwarding business, this includes hauliers, overseas agents, warehouses, fulfilment providers, labour providers and subcontractors. Risk factors include the country and sector, use of agency or migrant labour, subcontracting, recruitment practices and unusually low prices.
Checks may include verifying the business and its recruitment arrangements, reviewing relevant policies or modern slavery statements, asking targeted questions and seeking evidence or further assurance where risks are higher. A signed declaration alone will not resolve credible warning signs.
AJF will communicate its standards and use appropriate contractual requirements to prohibit exploitation, require cooperation with enquiries and corrective action, and require relevant standards to be passed to subcontractors. Higher-risk relationships will receive closer review. Staff must raise concerns where pricing, deadlines or other commercial pressures could encourage exploitation.
5 Recognising and reporting concerns
Warning signs may include workers who appear frightened or controlled, cannot speak freely, lack access to their documents or wages, face recruitment debts, work excessive hours, or live in accommodation controlled by an employer or intermediary. These signs are indicators requiring attention, rather than proof on their own.
Report any concern promptly to your line manager or directly to the Director. Managers must refer concerns to the Director promptly. You do not need proof before raising a reasonable concern.
AJF has one Director. If a concern involves the Director, or you feel unable to use the internal route, you may report directly to the police or seek confidential advice from the UK Modern Slavery and Exploitation Helpline on 08000 121 700. In the UK, call 999 if anyone is in immediate danger, or 101 for a non-emergency police report. Outside the UK, use the relevant local emergency or reporting service. No company permission is required to make a lawful external report.
Do not confront a suspected exploiter, attempt a rescue or investigate independently. Do not promise absolute confidentiality. Record relevant facts securely where safe, preserve existing evidence and avoid any action that could increase danger to a potential victim.
6 Responding to concerns and protecting people
The Director will assess concerns promptly, prioritise the safety and welfare of those affected, and obtain specialist advice or involve the appropriate authorities where necessary. AJF will cooperate with lawful investigations and seek appropriate support for potential victims. A concern involving the Director may be referred through the external routes above.
Reports and personal information will be handled sensitively and securely, shared only where necessary for a legitimate purpose or required by law. AJF will consider the wishes and safety of potential victims and applicable safeguarding requirements when deciding what information to share.
No one will suffer retaliation or detrimental treatment for raising a concern based on a reasonable belief, assisting an appropriate investigation or refusing to participate in exploitation, even if the concern is not substantiated. Nothing in this policy restricts protected whistleblowing disclosures or lawful reports to authorities.
7 Breaches and corrective action
A breach by an employee may result in disciplinary action, up to and including dismissal, following a fair procedure and the applicable disciplinary policy. Serious involvement in exploitation may amount to gross misconduct and may also be a criminal offence.
Where a supplier or other partner presents a risk or breaches this policy, AJF will assess the evidence and agree suitable corrective action where appropriate. This may include protecting affected workers, remedying recruitment fees, improving working conditions, closer monitoring, suspension or termination under the relevant contract. AJF will consider the impact on affected people before withdrawing business and will not treat ending a contract as a substitute for safeguarding or appropriate reporting.
8 Responsibility training and review
The Director is responsible for implementing this policy, maintaining appropriate risk assessment and due diligence records, overseeing responses to concerns and communicating expectations. Managers must apply the policy and employees must cooperate with its requirements.
AJF will provide proportionate information and training, particularly for staff involved in recruitment, procurement and managing suppliers. The Director will review the policy at least annually and following significant changes, concerns or identified weaknesses. Reviews will consider risks identified, checks completed, training and the effectiveness of corrective action.
The Director will assess whether AJF is required to publish an annual slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015. Where that requirement applies, AJF will prepare, approve, sign and publish the statement in accordance with the law. This policy is separate from any required annual statement.
Created 2019-08-10
Last updated 2026-11-10