RS Wheel Refurbishment Ltd Modern Slavery and Human Trafficking Policy

Last updated Dec 2025

1. Policy Statement

Modern slavery and human trafficking are serious crimes and violations of fundamental human rights. They take many forms, including slavery, servitude, forced or compulsory labour, bonded labour, child labour, sexual exploitation, and domestic servitude. These practices deprive individuals of their freedom for personal or commercial gain.

About Our Organisation

RS Wheels Refurbishment Ltd operates in the United Kingdom, providing alloy wheel repair and refurbishment services to customers, trade partners, and commercial clients. Our activities include the inspection, repair, refinishing, and refurbishment of alloy wheels to restore safety, performance, and appearance.

We are committed to conducting our business responsibly, ethically, and transparently.

This policy sets out our commitment to preventing modern slavery and human trafficking within our operations and supply chains, in line with:

  • The UK Modern Slavery Act 2015

  • International Labour Organisation (ILO) conventions

  • UN Guiding Principles on Business and Human Rights

  • OECD Due Diligence Guidance

  • Emerging UK and international ESG and human rights standards (2025–26)

2. Our Commitment

We are committed to:

  • Acting ethically and with integrity in all business relationships

  • Respecting human rights across our operations and supply chains

  • Complying with all applicable employment, labour, and supply-chain legislation in the countries in which we operate

  • Maintaining a zero-tolerance approach to modern slavery and human trafficking

This policy applies to all persons acting on our behalf, including:

  • Employees (at all levels)

  • Directors and officers

  • Consultants, contractors, and agency workers

  • Volunteers and interns

  • Business partners, suppliers, and subcontractors

3. Supply Chain Management and Due Diligence

We recognise that supply chains can present higher risks of modern slavery, particularly where goods or services are sourced from high-risk sectors or regions.

We therefore commit to the following measures:

Supplier Standards

We will not knowingly support or engage with any organisation involved in modern slavery or human trafficking.

Risk Assessment and Due Diligence

  • We assess modern slavery risks when onboarding new suppliers and periodically review existing suppliers.

  • Enhanced due diligence is applied where risks are higher, including:

  • Overseas suppliers

  • Labour-intensive industries

  • Use of temporary, migrant, or subcontracted labour

Supplier Expectations

  • Suppliers are expected to:

  • Comply with all applicable labour and human rights laws

  • Maintain policies and controls to prevent modern slavery

  • Permit audits, assessments, or information requests where appropriate

Continuous Improvement

Where risks are identified, we will work collaboratively with suppliers to improve standards. Where serious or unremedied breaches occur, relationships may be terminated.

4. Roles and Responsibilities

Governance and Oversight

The Board of Directors & Senior Management Team has overall responsibility for:

  • Approving this policy

  • Ensuring appropriate resources and controls are in place

  • Reviewing progress and compliance annually

Management Responsibilities

  • Line managers are responsible for:

  • Ensuring team members understand and comply with this policy

  • Identifying and escalating potential risks

Employee Engagement

All employees are encouraged to contribute to continuous improvement.

Comments, concerns, or suggestions regarding this policy should be directed to: Nicole Baxter-Leigh, HR & Office Manager

5. Compliance and Reporting

Employee Obligations

All staff must:

  • Read, understand, and comply with this policy

  • Avoid any activity that could lead to a breach

Raising Concerns

  • Employees must report any suspicion or belief that modern slavery is occurring or may occur within our business or supply chains

  • Reports should be made to a line manager or via established whistleblowing channels

Whistleblowing Protection

  • We are committed to protecting whistleblowers. Concerns can be raised confidentially and without fear of retaliation.

6. Training and Communication

Training

We provide appropriate training to employees, particularly those involved in:

  • Procurement

  • Supply-chain management

  • Recruitment and labour management

Training is reviewed regularly to reflect emerging risks and legislative developments.

External Communication

Our zero-tolerance approach to modern slavery is clearly communicated to:

  • Suppliers

  • Contractors

  • Business partners

Expectations are reinforced through contracts, supplier codes of conduct, and ongoing engagement.

7. Breaches of Policy

Employees

Any employee found to have breached this policy may face disciplinary action, up to and including dismissal for gross misconduct.

Suppliers and Business Partners

  • Breaches by suppliers, contractors, or partners may result in:

  • Remedial action plans

  • Suspension of work

  • Termination of contracts

8. Review and Approval

This policy is reviewed annually and updated as required to reflect:

  • Legislative changes

  • Best practice developments

  • Emerging risks