Modern Slavery & Human Trafficking Statement

1. Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

T Brown Group is committed to improving our practices to combat modern slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes T Brown Group’s modern slavery and human trafficking statement for the financial year ending March 2023.

2. Our Business

T Brown Group is a Private Limited Company incorporated in England and Wales with the registered number 1006630. The Registered Office is at Ground Floor Bluebird House, Station Road, Leatherhead, Surrey, United Kingdom, KT22 7BA. T Brown Group is a professional facilities services firm providing repair, maintenance and installation and building works to several local authorities and social housing landlords. T Brown Group has offices in England and Wales only, with no international offices or presence.

T Brown Group are opposed to all kinds of slavery and human trafficking in our direct and indirect operations, and our supply chain as a whole. T Brown Group are regulated and / or accredited by various professional bodies including:

  • Gas Safe
  • The Environment Agency
  • Contractors’ Health and Safety Assessment Scheme (CHAS)
  • Constructionline
  • Information Commissioner’s Office
  • Electrical Contractors Association
  • TrustMark Accreditation

The company currently employs approximately 375 staff and had an annual turnover of £45m

3. Services

The services T Brown Group provides to its clients are predominantly site or office based (sites and offices being located in the UK only). The T Brown Group Limited supply chain, in relation to services, consists, on the whole, of other regulated or professional services. T Brown Group Limited considers these to be very low risk in relation to slavery and human trafficking, so takes no specific action in relation to these associations. T Brown Group’s Code of Conduct sets out the behaviour we expect from employees in their dealings with colleagues, customers, suppliers, agents, and intermediaries. All employees and suppliers are expected to act with integrity and in accordance with the standards of behaviour set out in the Code of Conduct.

The majority of other services supplied to T Brown Group are professional services associated with running a limited company, for example banking, auditing, insurance and professional consultancy services. T Brown Group vets its external contractors, related to the industry, to ensure they have the requisite accreditations and are appropriately qualified for the roles they are asked to undertake. These services are again UK based and T Brown Group considers them lower risk areas of activity and so takes no additional steps over and above our supplier approval process.

Given what T Brown Group understands to be a low risk profile of anyone supplying us with services being involved in slavery and/or human trafficking, we believe our current procedures and ability to rely on regulatory oversight in relation to professional services, are sufficient in this regard. Given this low risk profile, no specific training is provided or undertaken by our staff in relation to these matters

4. Goods

In terms of goods supplied to T Brown Group, the majority of goods will be for use in an on-site, or office environment. Occasionally T Brown Group will be supplied with goods for use outside an office environment, for example “personal protective equipment”.

Given what T Brown Group understands to be a low risk profile of suppliers of goods, no specific training is provided or undertaken by T Brown Group staff in relation to these matters. However, T Brown Group does have a number of relevant polices that demonstrates our commitment to act with integrity and ensure that there is no slavery or human trafficking part of the business, namely the following:

  • Code of Conduct
  • Intercultural Code of Conduct
  • Environmental Policy Statement
  • Health and Safety Policy Statement
  • Equality, Diversity Policy Statement
  • Corporate Social Responsibility Policy
  • Communications Policy
  • Sustainability Policy
  • Monitoring policy for Racial Equality

5. Our policies on modern slavery & human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We do not have key performance indicators specifically in relation to slavery or human trafficking as any instance would be expected to be a non-compliance and breach of employment laws, our direct employment practices, Code of Conduct and/or Supplier Standards. However, in light of the obligation to report on measures to ensure that all parts of our business and supply chain are modern slavery free, we continually review our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our workplace policies and procedures demonstrate our commitment to:

  • Acting ethically and with integrity in all our business relationships
  • Implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our supply chains

T Brown Group has in place strong policies, due diligence and risk assessment processes pertaining to risk management, safeguarding, whistleblowing and complaints. This is to ensure that where modern slavery is suspected, this can be managed sensitively and appropriately with the correct safeguards in place. T Brown Group recognises the responsibilities we have towards our clients, customers, independent contractors, and staff. We also encourage both contractors and staff to report any concerns. Our periodic contextualised safeguarding training for all front line and call centre employees as well as our Vulnerable Adults and Safeguarding Children policies have been developed in accordance with national and local safeguarding legislation and guidance. They include guidance on recognising a suspected human trafficking victim.

6. Due diligence processes for modern slavery and human trafficking

  • As part of our initiative to identify and mitigate risk of modern slavery and human trafficking in our organisation and our supply chain we:
  • Adhere to the National NHS Employment Checks/Standards. These include checks regarding employees’ UK address, right to work in the UK and obtaining suitable references. We also ensure agencies are on our approved suppliers list
  • ensure our staff receive fair pay rates and contractual terms through our Remuneration Committee
  • ensure all procurement and purchasing is conducted in line with T Brown Group policies
  • protect whistle blowers and encourage contractors and staff to report concerns where identified.
  • expect companies we engage with to ensure their goods, materials and labour-related supply chains fully comply with the Modern Slavery Act 2015 and are transparent, accountable, and auditable.

7. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide and will continue to provide training to our staff.

The Modern Slavery Act 2015 and its explanatory notes are available at:

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation

8. Requirement for annual review of this statement

This statement will be reviewed on an annual basis to ensure it reflects the work T Brown Group undertakes in improving our practices to combat modern slavery and human trafficking.

This statement was approved by the Board of Directors on 1 April 2023