Anti-Slavery & Human Trafficking Policy

Policy Statement

Estilo Interiors Ltd is committed to conducting business ethically, responsibly and transparently. We have a zero-tolerance approach to modern slavery, forced labour, servitude and human trafficking in all parts of our business and supply chains.

We recognise our responsibility to help prevent exploitation within the construction and interior fit-out sector and are committed to acting in accordance with the Modern Slavery Act 2015 and all relevant UK legislation.

This Policy supports our wider commitment to equality, dignity, respect and human rights as set out in our Equality, Diversity & Inclusion Policy.

Scope

This Policy applies to:

  • All employees of Estilo Interiors Ltd

  • Directors and senior management

  • Agency workers and subcontractors

  • Suppliers, manufacturers and service providers

  • Business partners and consultants

It applies across all business activities, including office operations, site-based works, procurement, labour supply and logistics.

Definitions

Modern Slavery includes slavery, servitude, forced or compulsory labour and human trafficking.

Human Trafficking refers to the recruitment, movement, harbouring or receipt of persons through coercion, deception or abuse of power for the purpose of exploitation.

Our Business & Supply Chains

Estilo Interiors Ltd operates within the commercial interior fit-out and refurbishment sector in the UK. Our supply chains may include:

  • Construction materials and furnishings

  • Specialist subcontractors and trades

  • Temporary and agency labour

  • Logistics and waste management providers

We acknowledge that some areas of construction and manufacturing supply chains can carry a higher risk of modern slavery and we actively work to mitigate these risks.

Responsibilities

Board & Senior Management

  • Overall responsibility for ensuring this Policy is implemented effectively

  • Ensuring appropriate resources, training and governance are in place

Managers & Site Leads

  • Ensuring compliance on projects and sites

  • Monitoring subcontractors and labour practices

  • Escalating concerns promptly

Employees & Contractors

  • Acting in accordance with this Policy

  • Remaining vigilant and reporting concerns

Risk Assessment & Due Diligence

Estilo Interiors Ltd adopts a risk-based approach to managing modern slavery risks by:

  • Assessing suppliers and subcontractors based on location, labour type and industry risk

  • Prioritising UK-based suppliers where possible

  • Conducting pre-appointment checks on subcontractors and labour agencies

  • Requesting confirmation of compliance with modern slavery legislation

Where higher risk is identified, enhanced due diligence measures may be applied.

Supplier & Subcontractor Expectations

We expect all suppliers and subcontractors to:

  • Comply with the Modern Slavery Act 2015

  • Pay workers at least the legal minimum wage

  • Ensure workers are free to leave employment

  • Prohibit the use of forced, bonded or trafficked labour

  • Allow workers to retain control of identity documents

Where appropriate, contractual terms will include clauses addressing modern slavery and ethical labour practices.

Training & Awareness

Estilo Interiors Ltd will:

  • Provide appropriate training and guidance to employees involved in procurement, project management and site operations

  • Raise awareness of the signs and indicators of modern slavery

  • Ensure staff understand how to report concerns

Reporting & Whistleblowing

Any concerns or suspicions relating to modern slavery or human trafficking must be reported immediately.

Reports may be made to:

  • A line manager

  • Senior management

  • The Company’s whistleblowing channel

All reports will be taken seriously, investigated promptly and treated confidentially. No individual will suffer retaliation for raising concerns in good faith.

Breaches & Remedial Action

Any breach of this Policy may result in:

  • Disciplinary action for employees

  • Termination of contracts with suppliers or subcontractors

  • Reporting to relevant authorities where required

We will work with suppliers to address issues where possible but reserve the right to disengage where serious or persistent breaches occur.

Monitoring & Effectiveness

We measure the effectiveness of this Policy through:

  • Supplier reviews and performance monitoring

  • Incident reporting and investigation outcomes

  • Training participation and awareness levels

Review & Approval

This Policy will be reviewed annually and updated to reflect:

  • Changes in legislation

  • Industry best practice

  • Business growth and supply chain changes

 

Andrew Moore, Founder & Managing Director

1st January 2025