Modern slavery statement

Organisation

This statement applies to Swale Heating Ltd (referred to in this statement as “the Organisation”). The information included in the statement refers to the financial year 2023.

Organisational structure

The company’s Head Office is in Sittingbourne, Kent with most of our business across London, the South East and East Anglia. The company was established in 1972 by Ian Pierson. In November 2023, Swale Heating Ltd was acquired by The Sureserve Group.

Swale Heating is one of the UKs largest installers of boilers and heating systems including boiler repairs, servicing, sales, and maintenance, servicing commercial and domestic clients. Whilst we operate year round, the winter months often require additional labour. All our labour is sourced in the UK.

Definitions

The Organisation considers that modern slavery encompasses:

• human trafficking
• forced work, through mental or physical threat
• being owned or controlled by an employer through mental or physical abuse of the threat of abuse
• being dehumanised, treated as a commodity or being bought or sold as property
• being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation — in the UK or abroad — which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to material suppliers and merchants, as well as trade subcontractors and plant suppliers. The Organisation’s first tier suppliers are intermediary traders and have further relationships with other manufacturers and lower tier suppliers, We work with our first tier suppliers to ensure modern slavery is not present in any part of our supply chain.

Potential exposure

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist primarily in the area of subcontractors employing casual labour, or one-off trade suppliers operating outside the UK/EU. The Organisation judges these suppliers to have highest risk of not having a comprehensive modern supply chain policy, or audit process.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with s.54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

• reviewing your supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
• measures in place to identify and assess the potential risks in its supply chains
• undertaking impact assessments of its services upon potential instances of slavery
• creating action plans to address risk to modern slavery
• any actions taken to embed a zero tolerance policy towards modern slavery
• any training provided to staff on modern slavery.

Key performance indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

• An annual review on first-tier suppliers to including a questionnaire to judge their risk of modern slavery, and steps they may be taking to mitigate.
• Confirmation from any new suppliers that they are not involved in modern slavery, and have/haven’t developed their own policy on it.
• A focus on what the Organisation deems as higher risk to track their compliance with an expectation in lowering their risk potential over time.

Policies

The Organisation has the following policies which further define its stance on modern slavery: a corporate social responsibility policy; supplier code of conduct; recruitment policy.

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to who all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations. 

This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.