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.
This is a responsibility shared by all those we work with, and so we regularly train our employees and suppliers and have policies and frameworks in place to enable individuals to take action.
Our Structure and Supply Chain
COOMBES has 95 employees, of which 51% are based either in one of our Hampshire offices or our office in Kent, and approximately 150 contingent workers, who are predominantly based across south-central England. These workers are made up of sub-contractors, agency workers and consultants, all of whom reside in England. COOMBES and its operations are entirely based in the UK.
Operating in the rail, forestryand 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.
To achieve its business objectives, COOMBES purchases or hires heavy plant machinery, vehicles, tools, materials, 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.
Our Policies
We have a number of policies (detailed below) that provide the governance and the frameworks to support the identification and eradication of modern slavery and human trafficking within COOMBES’s operations. These inform employees, our supply chain and our clients of our approaches to tackling modern slavery and the role they also play in this.
• Anti-Slavery & Human Trafficking policy
• Whistleblowing policy
• Code of Conduct
• Anti-bribery & Corruption policy
• Procurement policies
These policies are accessible to clients and suppliers on our website, and our employees can also access them on our shared internal drive.
These policies are reviewed regularly, and at least annually.
Training and Awareness
Modern Slavery awareness training is delivered to new employees at induction and is bespoke to the industries in which we operate to support effective identification of potential signs of slavery. Training is tailored to the audience and the environments within which they work, with site managers being coached to support whistleblowers. Refresher training is delivered routinely.
As part of our Approved Supplier Process, recruitment agencies and providers of contingent labour are required to undergo Modern Slavery awareness training at induction.
Contingent workers are mandated to attend COOMBES’s Supplier Liaison Days (held quarterly), at which we talk about the signs of Modern Slavery and how concerns can be raised.
On Anti-Slavery Day each year COOMBES holds an awareness campaign that highlights the potential signs of modern slavery and human trafficking. Communications extend to our employees and indirect workers which promote reporting and whistleblowing channels.
Following consultation with our delivery teams, we have designed Modern Slavery Toolbox Talks that are impactful and are rolling these out across our workforce.
Due Diligence
COOMBES recognises that due diligence processes and reporting are essential management tools that improve risk identification. We have tailored approaches for both our supply chain and our employees, which are detailed below.
Suppliers and Contractors
We undertake stringentdue diligence processes to ensure we only use suppliers and contractors whoshare our commitment to ethical practices. By working to secure a transparent supply chain through operating duediligence, COOMBES seeks to prevent modern slavery from occurring in the courseof our operations.
We undertake thefollowing courses of due diligence:
Employees
We conduct all businessin 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, as we undertake the following measures of due diligence:
Effectiveness
Details of audits are reviewed and discussed at periodic compliance meetings. Individual SMART action plans are revisited and ensure that steps are being taken within the specified deadlines.
Modern Slavery training has been rolled out to 100% of our employees within our Commercial, Procurement, Finance, Quality & Compliance, Health & Safety and HR teams.
Future Performance Indicators
In 2025/26, we are rolling out company-wide refresher training to our line managers on our Employee Handbook, including a module specifically around Modern Slavery and their role in helping to identify risk and escalating potential/actual issues. We also have plans to design and deliver interactive surgeries to our supply chain/contractors on our Code of Conduct.
We will add Modern Slavery as a category to our Close Call reporting system, to support ease of reporting concerns.
In October 2025, COOMBES will once again 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.
COOMBES takes responsibility for this Statement and its related objectives, and to review and update it in accordance with the Act.
Shane Coombes, Managing Director
March 2025
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