Classic Builders (Southwest) Limited is committed to eliminating slavery within the construction industry and associated supply chains

Policy Statement

This policy applies to all persons working for or on behalf of Classic Builders South West Ltd (“the Company”) in any capacity, including employees, directors, agency workers, subcontractors, consultants and suppliers.

 

The Company maintains a zero-tolerance approach to modern slavery and human trafficking. Classic Builders is committed to acting ethically, with integrity, and to implementing effective systems and controls to ensure that modern slavery is not taking place anywhere within the business or supply chains.

 

Modern slavery is a criminal offence and a violation of fundamental human rights, encompassing slavery, servitude, forced or compulsory labour, bonded and child labour, and human trafficking.

 

This policy is issued in accordance with Section 54 of the Modern Slavery Act 2015 and reflects the expectations of publicly funded clients, including UK local authorities, the NHS and the Ministry of Defence, in relation to transparency, ethical procurement and responsible supply chain management.

 

Organisation Structure, Business and Supply Chains (Section 54(a))

Classic Builders South West Ltd is a privately owned building contractor operating across the South West of England with an annual turnover of approximately £80 million. The Company employs around 140 direct staff and engages a supply chain of approximately 600 subcontractors, suppliers and labour providers.

The Company delivers construction services including minor works, new build housing, commercial, healthcare and hospitality projects, defence sector works, listed and heritage building refurbishments, and domestic and commercial refurbishment and conversion projects.

The supply chain includes specialist subcontractors, labour-only subcontractors, recruitment agencies and materials suppliers. In line with the expectations of public sector clients, Classic Builders recognises that risks may extend beyond direct suppliers into lower tiers of the supply chain, particularly where labour provision, agency working, or overseas sourcing is involved.

 

Policies in Relation to Slavery and Human Trafficking (Section 54(b))

The Company operates a suite of policies supporting its commitment to preventing modern slavery, including this policy, Anti-Bribery and Corruption Policy, Whistleblowing Policy, and Equality and Diversity Policy.

Classic Builders expects all individuals working for or on its behalf to uphold these standards. Suppliers and subcontractors are required to comply with all applicable legislation, including the Modern Slavery Act 2015, and to implement equivalent standards within their own organisations and supply chains.

In line with public sector procurement requirements, modern slavery considerations are embedded into contractual arrangements, including provisions relating to –

• compliance with legislation and ethical standards
• flow-down of obligations through the supply chain
• rights to request information and evidence of compliance
• appropriate remedies in the event of non-compliance

 

Due Diligence Processes (in accordance with Section 54(c))

Classic Builders adopts a proportionate and risk-based approach to due diligence across its operations and supply chain, consistent with UK Government guidance and public sector expectations.

During procurement and pre-qualification, the Company assesses suppliers’ suitability, including their policies, labour practices and approach to managing modern slavery risks. This process aligns with commonly used public sector selection criteria and standard questionnaires.

Following appointment, suppliers and labour providers are required to demonstrate ongoing compliance with Company standards. Classic Builders maintains oversight through site-based monitoring, workforce verification checks, and periodic review of supplier performance.

Where higher-risk activities are identified, additional due diligence may be undertaken. This may include targeted audits, engagement with suppliers to improve controls, and verification of labour sourcing practices. Any concerns are investigated promptly, with appropriate steps taken to safeguard affected individuals and ensure corrective action is implemented.

 

Risk Assessment and Management (in accordance with Section 54(d))

Classic Builders recognises that modern slavery risks may arise in areas such as labour-only subcontracting, agency labour, lower-tier supply chain arrangements and the employment of migrant workers.

In response, the Company applies a structured approach to risk assessment that reflects the expectations of public sector clients and guidance on responsible sourcing. This includes maintaining visibility of workforce arrangements, engaging directly with key suppliers, and ensuring that employment practices are transparent and compliant with legal requirements.

The Company seeks to reduce risk by limiting unnecessary subcontracting tiers, promoting responsible procurement practices, and ensuring that those engaged in the supply chain understand and meet required standards.

Risk management is subject to ongoing review, with findings used to inform improvements in processes and controls.

 

Effectiveness and Performance Monitoring (in accordance with Section 54(e))

The effectiveness of Classic Builders’ approach is monitored through internal review processes and performance measures aligned with public sector expectations for transparency and accountability.

This includes monitoring supply chain compliance, reviewing workforce verification processes, tracking and investigating reported concerns, and assessing supplier adherence to contractual and ethical requirements.

Outcomes from these activities are reported internally and used to support continuous improvement. Where appropriate, information may be shared with clients to demonstrate compliance with contractual and statutory obligations.

 

Training and Capacity Building (in accordance with Section 54(f))

Classic Builders is committed to ensuring that employees have the knowledge and capability to identify and address modern slavery risks.

Training is provided at induction and supported by role-specific guidance for those involved in procurement, commercial management and site operations. This ensures that personnel understand how to recognise indicators of exploitation and respond appropriately.

The Company also communicates expectations to the supply chain and promotes awareness through engagement, supporting a consistent approach across all projects, including those delivered for public sector clients.

 

Reporting, Whistleblowing and Remediation

All individuals working for or on behalf of Classic Builders are responsible for identifying and reporting concerns relating to modern slavery.

Concerns may be raised through line management or via the Company’s whistleblowing procedures. Reports are handled confidentially where possible and investigated promptly and appropriately.

Where instances of modern slavery are identified, Classic Builders is committed to taking responsible and proportionate action. This includes prioritising the welfare of affected individuals, working with relevant organisations where appropriate, and addressing the root causes of any issues identified within the supply chain.

 

Governance and Approval

This statement is made in accordance with Section 54 of the Modern Slavery Act 2015 and is reviewed annually.

It is approved by the Board of Directors and signed by a Director on behalf of Classic Builders. The statement is published on the Company’s website in a prominent location, in line with statutory requirements and public sector expectations.

 

Continuous Improvement and Public Sector Commitment

Classic Builders recognises that tackling modern slavery is an ongoing responsibility and is committed to continuous improvement. This includes strengthening supply chain engagement, enhancing due diligence processes, and aligning with evolving UK Government policy, including procurement policy notes and best practice guidance. The Company supports the principles of transparency, accountability and social value that underpin public sector procurement and remains committed to working collaboratively with clients to uphold these standards.

 

Signed	Electronic Signature
Name	Adam Brimacombe
Date	09.04.26