Introduction
This policy ensures that Conservatory Outlet Holdings Limited and its subsidiaries (“the Group”) complies with s.54 of the Modern Slavery Act 2015 and sets out the responsibilities for employers and employees.
Conservatory Outlet Group is committed to ensuring that all its business operations and supply chains are free from involvement with slavery or human trafficking. We take a zero-tolerance approach to any form of modern slavery including slavery, servitude, forced or compulsory labour and human trafficking.
We are committed to acting ethically and with integrity in all business relationships and to implementing effective systems and controls to ensure modern slavery does not take place within our operations or supply chains.
Annual Statement
Conservatory Outlet Group will publish an annual slavery and human trafficking statement. A link to this statement will be on the homepage of the website and will be signed by Greg Kane – CEO following approval by the board of directors.
Karen Starkey – Head of HR is responsible for ensuring this statement is published and reviewed on an annual basis.
This statement will help explain the steps that Conservatory Outlet Group has taken to ensure that slavery and trafficking are not taking place in any of its supply chains, or in any part of its own business.
Scope
This policy applies to:
- All employees, workers, directors and officers of the Group
- Agency workers, contractors, consultant and temporary staff
- Suppliers, subcontractors, and business partners operating on behalf of the Group
Compliance with this policy is mandatory.
Responsibilities
- The Board has overall responsibility for ensuring this policy is implemented effectively.
- Senior management are responsible for embedding this policy within operations and supply chains.
- Employees and workers are responsible for complying with this policy and reporting concerns.
Our Business
Conservatory Outlet Group operates in the design, manufacture, supply, and installation of home improvement and building products, serving residential and commercial customers in the UK.
Our operations involve direct employment, the use of agency labour, and engagement with a range of suppliers and subcontractors. As such, we recognise that modern slavery risks can arise both within our own operations and across our wider supply chain.
Risk Assessment
The Group recognises that the primary areas of potential risk for modern slavery may include:
Supply Chain
- Procurement of raw materials, components, or finished goods, including items that may originate from overseas
- Use of subcontractors for installation or specialist services
- Multi‑tier supply chains where visibility may be reduced
People and Labour
- Use of recruitment agencies and temporary labour
- Risk of non‑compliance with minimum wage, working time, or right‑to‑work requirements
The Group considers these risks manageable through appropriate due diligence and ongoing controls.
Due Diligence and Controls
To mitigate modern slavery risks, the Group commits to:
- Working with reputable suppliers and contractors who share our ethical standards
- Conducting due diligence on new suppliers, contractors, and recruitment agencies
- Seeking to include modern slavery and ethical compliance clauses in supplier and subcontractor agreements
- Periodically reviewing supplier and agency relationships based on risk
- Reviewing modern slavery risks as part of any acquisition or business integration activity
Where concerns are identified, the Group will take appropriate action, which may include remediation, additional monitoring, or termination of the relationship.
Employment Practices
The Group is committed to fair and lawful employment practices, including:
- Ensuring all workers have the legal right to work
- Paying all employees and workers in accordance with applicable minimum wage and employment legislation
- Prohibiting cash‑in‑hand payments
- Maintaining clear employment contracts and transparent terms and conditions
Employees are expected to act in accordance with the Group’s ethical standards and policies at all times.
Training and Awareness
The Group will provide training and awareness activities to ensure that relevant employees understand:
- What modern slavery and human trafficking are
- How to identify potential warning signs
- How to raise concerns
Training is targeted at roles where the risk of exposure is higher and is refreshed periodically to maintain awareness.
Reporting Concerns (Whistleblowing)
All employees and workers are encouraged to report any concerns relating to modern slavery or unethical practices.
Concerns may be raised through:
- Line management
- HR
- The Group’s whistleblowing procedures
Reports will be treated seriously, investigated appropriately, and handled confidentially where possible. No individual will suffer retaliation for raising concerns in good faith.
Continuous Improvement
As the Group grows or its operations change, safeguards will be strengthened as necessary.
Additional Action Points
In addition to producing the annual statement, Conservatory Outlet Group is committed to:
- Ensuring that slavery and human trafficking is considered and addressed in our approach to corporate social responsibility.
- Carrying out regular audits to ensure that all our employees are paid at least the National Minimum Wage and have the right to work in the UK.
- Appointing a named individual to oversee the compliance with the Modern Slavery Act 2015 (this person is Karen Starkey – Head of HR).