Modern Slavery Statement | Richmond & Towers

Modern Slavery Statement


This statement applies to Richmond & Towers (referred to in this statement as ‘the Organisation’).

The Organisation considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat
  • being owned or controlled by an employer through mental or physical abuse of the threat of abuse
  • being dehumanised, treated as a commodity, or being bought or sold as property
  • being physically constrained or to have restriction placed on freedom of movement.


We acknowledge our responsibilities in relation to tackling modern slavery and commit to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

We do not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Richmond & Towers is obtained by means of slavery or human trafficking. We strictly adhere to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

Potential exposure

In general, the Organisation considers its exposure to slavery/human trafficking to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.


The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

  • sending our Supplier Code of Conduct and Modern Slavery Statement to all our suppliers informing them we will cease trading and terminate any contract if they are suspected or found guilty of Modern Slavery
  • training taken to embed a zero-tolerance policy towards modern slavery
  • training provided to staff on modern slavery

Key performance indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

  • annual review to ensure modern slavery is not taking place within supply chains or the organisation
  • annual training of staff on modern slavery


The Organisation has the following policies which further define its stance on modern slavery; Supplier Code of Conduct, CSR policy, Diversity Policy and Recruitment policy. Available on request from

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer (Andrea Garvey), to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Nikki Thomson, CEO