Approved by Raymond Cullen, Managing Director — next review January 2027
Cullen Utilities Ltd is committed to preventing slavery, human trafficking and illegal working in our business and our supply chains, in line with the Modern Slavery Act 2015.
This policy sets out our commitment to compliance with the Modern Slavery Act 2015 and the steps we take to ensure there is no slavery, human trafficking or illegal working in our own business or our supply chains. We all have a duty to be alert to the risks, however small; staff are expected to report concerns and management to act on them.
This statement covers the activities of Cullen Utilities Ltd — a utilities contractor that excavates, repairs, replaces and refurbishes pipework and provides traffic management. The company operates in the United Kingdom.
To build understanding of the risks of modern slavery, human trafficking and illegal working, all employees attend a short modern slavery training presentation within the first two months of employment.
We carry out appropriate visa, passport and date-of-birth checks to ensure all current and prospective employees are entitled to work in the UK, in accordance with sections 15 to 25 of the Immigration, Asylum and Nationality Act 2006. Where someone has a time-limited right to work, additional checks are made to ensure their documents are renewed before that right would expire. All verification documentation follows Home Office guidance on preventing illegal working and is retained for at least two years after employment ends.
We undertake due diligence when taking on new suppliers and regularly review existing ones. This includes building long-standing relationships, making our expectations of business partners clear, evaluating the modern slavery and human trafficking risks of each new supplier, and invoking sanctions — up to terminating the relationship — against suppliers who fail to improve in line with an action plan we provide.
Where operatives have limited English, we make special arrangements so that information — particularly health and safety information — is comprehensible and relevant, in line with Regulation 10 of the Management of Health and Safety at Work Regulations. This may include translations, using interpreters, or replacing written notices with clear information in the language most used by those employees.
This policy is reviewed at regular intervals and updated as necessary. The company director endorses this statement and is fully committed to its implementation.