Modern Slavery Policy


Slavery is illegal and a violation of human rights. There are many forms of Modern Slavery including forced labour, child labour, exploitation, being controlled by an employer, debt bondage, being physically constrained, being sold, or treated as a commodity and having restrictions on freedom of movement. These acts involve a person losing their freedom by being exploited by another for personal or commercial gain.

HBL Associates Ltd has a zero-tolerance approach to Modern Slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. We will implement and enforce effective systems and controls to ensure Modern Slavery is not taking place in our own business and supply chains.

We are committed to ensuring our business is transparent, as such we will comply with the disclosure obligations under the Modern Slavery Act 2015.

HBL Associates Ltd expects our contractors, suppliers, and other business partners to uphold high standards in all business practices; as part of the contracting processes, we include prohibitions against the use of staff sourced from forced compulsory or trafficked labour, anyone held in slavery or servitude. HBL Associates Ltd expect their suppliers to hold these high standards.

HBL Associates Ltd will contact relevant suppliers to ensure they comply with the Modern Slavery Act 2015.

This policy applies to all persons working for, or on behalf of HBL Associates Ltd, in any capacity. This includes but does not limit the policy applicability to employees, agency workers, temporary staff, agents, contractors, external consultants, third-party representatives, and business partners.

This policy does not form part of any employee’s contract of employment, and we reserve the right to amend it at any time.


The Directors of HBL Associates Ltd have overall responsibility for ensuring this policy complies with HBL Associates Ltd legal and ethical obligations, and that all those under our control comply with it.

The Directors of HBL Associates Ltd have primary responsibility for implementing this policy. This includes responsibility for the monitoring of its use and effectiveness, auditing of internal control systems and procedures. The Directors are also responsible for updating the policy to reflect any changes in legislation.


All HBL Associates Ltd employees are responsible for the prevention, detection and reporting of Modern Slavery in any part of our business or supply chains. Employees are required to avoid any activity that might lead to a breach of this policy, and the Modern Slavery Act 2015.
Employees must notify their manager as soon as possible if they believe or suspect that, a conflict with, or breach of, this policy has occurred, or may occur, in the future.

Employees are encouraged to raise concerns about suspicions of Modern Slavery in any parts of our business or supply chains at the earliest possible stage (see 1.11).

If an employee is unsure whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any, or all, the various forms of Modern Slavery outlined in 1.1, follow 1.11.


As part of the induction process, all employees are advised on the policy including who to report it to. The topic is covered in the recruitment training completed by managers responsible for making recruitment decisions.

Our zero-tolerance approach to Modern Slavery is communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them. Suppliers are asked to comply with our Modern Slavery policy from the onset of the relationship. Suppliers who are unwilling to comply will not be engaged.


Any employee who breaches this policy will face disciplinary action. This could result in action up to dismissal in accordance with HBL Associates Ltd policies. We may terminate our relationship with other employees, suppliers and any other associates working with HBL Associates Ltd if they breach this policy.