Modern Slavery Statement

Modern slavery is a heinous crime and Coombes Forestry Ltd (“COOMBES”) operates a zero-tolerance commitment to slavery and human trafficking. Under the Modern Slavery Act 2015 (the “Act”), COOMBES is dedicated to ensuring that human trafficking, slavery, forced or compulsory labour and/or servitude does not take place at any point in our business or in our supply chains.

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Our Structure and Supply Chains

COOMBES has 70 employees and approximately 150 agency workers, who are predominantly based across south-central England. COOMBES and its operations are entirely based in the UK.

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Operating in the Rail, Forestry and Civil Engineering sectors, COOMBES bids to public, private and voluntary sector organisations for contracts for work through structured business development processes. We are also contracted directly by private landowners or businesses for forestry and vegetation works. Additionally, we hire out various heavy plant machinery, predominantly for use in the Rail and Forestry sectors.

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To achieve its business objectives, COOMBES purchases or hires heavy plant machinery, vehicles, tools, mechanical equipment, PPE (personal protective equipment), IT hardware and peripherals and office equipment. In doing so, COOMBES works with nearly 200 suppliers, all of which are based in the UK. COOMBES considers therefore, that there is a relatively low risk of modern slavery and/or human trafficking occurring within its supply chain.

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Due Diligence

COOMBES recognises that due diligence processes and reporting are essential management tools that improve risk identification.

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Suppliers and Contractors

We undertake stringent due diligence processes to ensure we only use suppliers and contractors who share our commitment to ethical practices. By working to secure a transparent supply chain through operating due diligence, COOMBES seeks to prevent modern slavery from occurring in the course of our operations.

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We undertake the following courses of due diligence:

• COOMBES has clear Supplier Application processes in place for supplier approval, which includes duediligence checks to assess the suitability of suppliers to provide goods and services against required standards.
• We require suppliers to commit to meeting the modern slavery and anti-human trafficking provisions set out in our Code of Conduct as part of their submission to COOMBES’s Approved Supplier List.
• All suppliers are required to confirm, as part of the Supplier Application process, that there is no evidence of any modern slavery or human trafficking within their organisation, or that of their own supply chain.
• We undertake site inspections and conduct audits of our suppliers and their premises to check for any indications of modern slavery or human trafficking.
• We obtain Modern Slavery statements from suppliers, where available.
• Vet suppliers so far as possible of their own compliance requirements of the legislation, including whether they have been convicted of an offence under the Moder Slavery Act 2015.
• Our supply chain is routinely analysed by our Quality and Finance teams.
• Suppliers are removed from COOMBES’s Approved Supplier List after 12 months of inactivity. Suppliers are required to complete the registration process again to re-join.
• We promptly and thoroughly investigate any claims or indication that a supplier or contractor to COOMBES is engaging in slave labour or human trafficking or is otherwise not complying with our Code of Conduct.

Employees
We conduct all business in an ethical manner and are committed to being a transparent organisation. We do not consider there to be a high risk of slavery or human trafficking within COOMBES’s workforce; however we undertake the following courses of due diligence across the Company

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• Robust and documented recruitment processes incorporating ‘right to work’ document checks, proof of address, contracts of employment, payment of salaries into bank accounts under the respective employee’s name and ensuring everyone employed is 16 years or above. Identity and right to work checks are conducted at interview stage, with only original documentation accepted.
• Our HR and Payroll teams ensure that all COOMBES employees are in receipt of at least the National Minimum Wage.
• Our Employee Handbook has a range of procedures to support in preventing modern slavery from occurring in our work place.
• We honour our responsibility to protect whistle blowers who highlight to us any risk of slavery or human trafficking at COOMBES. We have a Whistle blowing Policy in place affirming this commitment, which also details the procedure for reporting concerns.
• Our open and inclusive culture set the parameters for how we expect people to interact with colleagues, partners and customers.
• Everyone at COOMBES is required to comply with legal requirements at all times.

Future Performance Indicators

In our business year 2023, COOMBES employees involved with our suppliers and contractors, in particular Purchasing, Commercial, Accounts and Managers, will undergo anti-slavery and human trafficking training. In October 2023, COOMBES will observe Anti-Slavery Day across the business and its operations, and campaign to raise awareness amongst employees and sub-contractors of the dangers and consequences of modern slavery, human trafficking and exploitation.

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COOMBES is growing our Commercial, Purchasing and Quality and Compliance teams in 2023, adding to the skills, experience and expertise already held in this area. This will further enhance our ability and capacity to ensure internal and external processes and systems relating to suppliers, contractors and employees are being adhered to, and identify areas for further improvement.

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Coombes takes responsibility for this Statement and its related objectives, and to review and update it in accordance with the Act.

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Shane Coombes, Managing Director

March 2023 

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