This Modern Slavery Policy sets out our zero tolerance approach to modern slavery and human trafficking. Last updated: 15 October 2026.
1. Purpose of This Modern Slavery Policy
Ingenious Partners Ltd has a zero tolerance approach to modern slavery and human trafficking, in line with the Modern Slavery Act 2015 and our ethical employment policy. This policy sets out how we prevent, identify and respond to the risk of modern slavery in our own business and in the supply chains through which we supply personal protective equipment, workwear and other goods to our customers. It supports the commitments we make to public sector and commercial customers.
2. What We Mean by Modern Slavery
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking, as set out in the Modern Slavery Act 2015. It also covers debt bondage, the withholding of wages or identity documents, the charging of recruitment fees to workers, the exploitation of children, and prison or penal labour that is not genuinely voluntary or that is compelled by the state, an employer or a third party.
Modern slavery can occur in any sector and at any tier of a supply chain. It can be hard to see, particularly where goods are made overseas, where materials such as cotton, leather and rubber pass through several countries before final manufacture, or where suppliers rely on agency or subcontracted labour. Garment, textile and footwear manufacture are recognised as higher risk areas.
3. Scope
This policy applies to our Director, to anyone who works for us or on our behalf, and to all of our suppliers, manufacturers, distributors, agents and other business partners, whether they are based in the UK or overseas.
4. Responsibility
The Director, Tracy Clarke, has overall responsibility for this policy, for making sure it is applied in practice and for reviewing it. Everyone covered by this policy must read it, understand it and avoid any action that causes or supports modern slavery. Anyone who has a concern must raise it as set out in section 10.
5. Standards We Expect of Suppliers
We expect every supplier and manufacturer to meet the standards in this section and to require the same of their own suppliers. Work must be freely chosen. There must be no forced, bonded, prison or trafficked labour, and workers must be free to leave their employment on reasonable notice. Workers must be free to move in and out of the workplace and any employer provided accommodation outside working hours, and must not be confined, locked in or otherwise restricted. Employers must not hold workers’ passports, identity documents or other personal papers, and must not charge workers recruitment fees or related costs.
Suppliers must not use child labour, and young workers must be protected from work that is hazardous or that harms their education or development. Workers must be paid on time at no less than the legal minimum wage or the applicable industry standard, whichever is higher, and their working hours must comply with local law. Overtime must be voluntary, paid at the correct rate and within legal limits, and workers must not be required to work overtime under threat of penalty or dismissal. Working conditions must be safe and hygienic, and workers must not be subjected to harassment, abuse, threats, violence or discrimination.
Workers must be free to join or form trade unions and to bargain collectively, and where this right is restricted by law, suppliers must allow other means for workers to associate freely and raise concerns without fear of reprisal. We also expect suppliers to be open with us about who makes our goods and where, and to tell us promptly if they use subcontractors or change the place of manufacture.
6. Due Diligence and Risk Assessment
For each relevant contract, we begin by mapping our direct suppliers and manufacturers, including the country of manufacture. We then seek information on the lower tiers of the supply chain, such as fabric mills and the origin of key materials, to understand where risks may be greater. We assess risk by looking at the country, the type of product, the nature of the labour involved and what we know about the supplier, using sources such as the Global Slavery Index and the US Department of Labor’s list of goods produced by child labour or forced labour.
This review is carried out at the start of each relevant contract and repeated at the midpoint of the contract term. We repeat it sooner where something changes, for example where we take on a new supplier, begin sourcing from a new country or region, or receive a concern. We keep a record of each supplier map, the risk rating we give each supplier and the evidence we relied on. As part of this assessment, we consider whether a country or supplier carries a known risk of state-imposed or other prison labour, using the same sources described above, and we treat this in the same way as any other forced labour risk.
7. Overseas and Higher Risk Suppliers
Suppliers and manufacturers outside the UK, and any supplier we assess as higher risk, are subject to additional assurance before we place orders. Depending on the level of risk, this may include a copy of the supplier’s own modern slavery or ethical trading policy, a signed supplier declaration or code of conduct, and independent audit reports or certifications relating to working conditions, including recruitment practices, where these are available. Where we buy through an established brand, we take account of the brand’s own ethical trading programme and audit requirements, but we still review the evidence and record our own assessment.
We will not knowingly source from any factory, region or supplier where we have credible evidence of forced labour. We take particular care with raw materials and components from regions that have been the subject of credible reports of state imposed forced labour, and we ask suppliers to tell us where key materials come from.
8. Our Purchasing Practices
We recognise that our own buying decisions can create pressure on suppliers that increases the risk of modern slavery. We aim to give suppliers realistic lead times and clear specifications, to avoid late changes to orders wherever we can, to pay on agreed terms, and not to press on price to a level that could only be met by cutting wages or working conditions. We ask suppliers to tell us if a deadline or price would put workers at risk of excessive overtime or unauthorised subcontracting, and we consider our own buying practices as part of each supplier risk review.
9. Onboarding and Supplier Terms
Before we use a new supplier, we ask them to confirm that they understand and will comply with the standards in section 5. Our Supplier Code of Conduct, which key suppliers sign when they are onboarded and reconfirm at least once every 12 months, sets out these requirements, including a commitment to tell us promptly about any concern, to cooperate with reasonable requests for information, and to pass these requirements on to their own suppliers.
10. Raising Concerns
Anyone who suspects or becomes aware of modern slavery, in our business or in any supply chain, should raise it with the Director as soon as possible, in writing or in person. The Director will record the concern, investigate it promptly and decide what action to take. This may include contacting the supplier, asking for corrective action, informing the relevant customer or the authorities, or pausing orders. Where a concern may affect goods supplied to a customer, we notify that customer immediately on becoming aware of it, or having reason to believe there may be one, and keep them informed until it is resolved.
If someone is in immediate danger, call 999. Concerns can also be reported to the Modern Slavery and Exploitation Helpline on 08000 121 700. We will not tolerate any detriment or retaliation against anyone who raises a concern in good faith.
11. Corrective Action and Remedy
Where we identify a concern with a supplier, our first priority is the safety and wellbeing of the workers affected. We will raise the concern with the supplier promptly and ask for a corrective action plan with a reasonable timescale. The plan should identify the root cause of the concern and any gaps in the supplier’s own processes, as well as the action being taken to correct them, and we will monitor progress.
Where workers have been harmed, we expect the supplier to provide access to remedy. This may include repayment of recruitment fees or unpaid wages, and safe exit or support for the workers concerned. We will work with the supplier and, where appropriate, the authorities or specialist support organisations to achieve this. We prefer to work with suppliers to improve conditions where that is possible, and we will avoid ending a relationship where doing so would leave workers worse off, but we will consider ending it if the concern is serious or is not resolved.
12. Vulnerable Worker Groups
We recognise that some groups of workers face a higher risk of modern slavery because of their circumstances, including migrant workers, agency and subcontracted labour, young workers, and workers who do not speak the local language. Overseas manufacturing for the goods we supply is more likely to involve migrant or agency labour, so we take particular care when assessing suppliers and factories in higher risk countries, as described in Sections 6 and 7.
Where we identify that a supplier or factory relies on migrant, agency or other vulnerable workers, we ask for additional assurance appropriate to that risk, such as evidence that recruitment fees are not charged, that identity documents are not withheld, and that workers understand their rights and pay in a language they understand. Where we become aware of a specific vulnerable worker, for example through a concern raised under Section 10, we prioritise their safety and wellbeing when deciding what action to take.
13. Quantitative Targets
We set the following measurable targets to improve our practice and that of our supply chain, and we report progress against them as part of the annual review described in Section 15. We will review and, where appropriate, increase these targets each year.
Within our own organisation, by 30 April 2027 we aim for 100% of relevant people (the Director and anyone else working for us or on our behalf) to have received the briefing described in Section 14 within the previous 12 months, and to have completed the annual risk assessment and review described in Section 6 for every relevant contract.
Within our supply chain, by 30 April 2027 we aim to hold a current supplier declaration and, where available, independent audit evidence for at least 80% of our overseas and higher risk suppliers by order value, rising to 100% by 30 April 2028, and to have completed a documented risk rating for every key supplier under the Supplier ESG Evaluation in our Environmental Management System.
14. Training and Communication
Everyone covered by this policy is briefed on it when they start working with us, when the policy is updated, and at least once every 12 months. Attendance is mandatory, and we record the date and who attended. The briefing covers the signs of modern slavery relevant to our sector and supply chains, including the International Labour Organization’s eleven indicators of forced labour and the risk of debt bondage linked to recruitment, how to raise a concern under section 10, and the outcome of each supplier risk review. Those involved in sourcing also receive a briefing on how to consider modern slavery risks in buying decisions, including the particular risks of overseas manufacturing and of the lower tiers of the supply chain. We share this policy with suppliers when they are onboarded. We cooperate fully with our customers’ own modern slavery due diligence, and on request we give them access to our supplier maps, risk assessments, supplier declarations and records of any concerns and their outcome.
15. Monitoring and Review
We keep records of supplier maps, risk assessments, supplier declarations, and any concerns raised together with their outcome. We track a small number of measures, such as the proportion of overseas and higher risk suppliers with a declaration and audit evidence on file and the proportion of relevant people who have been briefed, and to review them at least annually.
The Director will review this policy at least annually and in light of the outcome of supplier risk reviews, and sooner where there is a significant change to our business, supply chains or the risks we identify, including where we begin sourcing from a new country or region.