Modern Slavery Statement


21 recognise the importance of combatting slavery and human trafficking and we are pleased to play our part in combatting this.

The following Anti-slavery policy (the ‘policy’) states our intentions and commitment to improve our practices in line with the Modern Slavery Act 2015. The policy reflects our commitment to act ethically and with integrity in all our business relationships, to implement and enforce effective systems and controls to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business.


Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.
  • Engage minimum labour standards expected of the business in line with industry standards.
  • Factor in legal and fair full labour costs to reduce incentives for cheaper slave or bonded labour use in the supply chains.


Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme. We insist on only working with suppliers that can offer adequate assurance that they are not engaged in such activities; and which actively police this issue. We contractually require suppliers and subcontractors to monitor this issue as condition of working with them.



To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will provide training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.


Our effectiveness in combating slavery and human trafficking

We review supply-chain feedback each year on this issue to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.

We also monitor trade publications and news outlets in order to better understand the risks in our industry.


Further steps

We are committed to reviewing the effectiveness of the steps we have taken this year to ensure that here is no slavery or human trafficking in our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2020.



Signed for and on behalf of 21