Modern slavery statement

This statement sets out the measures SUEZ Recycling and Recovery UK Ltd (SUEZ) has in place and the actions we have taken during 2025. It demonstrates continuous improvement in managing the risk within our business and supply chains.

We recognise that slavery, servitude, forced labour and human trafficking (modern slavery) is a    world-wide and growing issue. The waste management and recycling sector has been specifically targeted by perpetrators of this type of crime. As a leading waste management and recycling business in the UK, the company recognises the need to adopt a robust approach to slavery and/or human trafficking and commits to identifying areas of risk within our business, and to develop strategies and approaches to mitigate those risks proactively.

After joining Slave-Free Alliance in September 2019, a gap analysis was conducted which SUEZ in the UK has used as the basis for improvement over the past four years. In January 2023, we commissioned Slave-Free Alliance to conduct a benchmarking activity to aid us with our continuous improvement in efforts (both internally and externally) to address and reduce the risks for modern slavery  and broader human rights violations.

SUEZ operates at over 250 sites across the UK with more than 7,000 people delivering our recycling and recovery services. 3.7% of our workforce are agency staff. Our business headquarters are in Maidenhead, UK. The following companies are covered by this statement:

• SUEZ Recycling and Recovery UK Ltd

• SUEZ Recycling and Recovery South East Ltd

• SUEZ Recycling and Recovery Lancashire Ltd

• SUEZ Recycling and Recovery Surrey Ltd

• SUEZ Recycling and Recovery Kirklees Ltd
• SUEZ Recycling and Recovery Suffolk Ltd
• F & R Cawley Ltd

Procurement and suppliers

We currently spend over £870 million per year across 3,600+ suppliers. Of this, over 95% is spent with UK-based companies.

Our supply chains are integral to delivering efficient and sustainable recycling and recovery services. We work closely with our suppliers to ensure they align with our values and standards, fostering partnerships that contribute to innovation, operational excellence and ethical practices across our business.

SUEZ has in place the following policies and procedures that set out its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Anti-Slavery and Human Trafficking Policy and Procedure – reviewed annually. 
• Whistleblowing Policy – Specifically includes modern slavery and human rights issues as reportable concerns within the whistleblowing process. SUEZ provides an independent whistleblowing hotline, which provides an easy and confidential means for concerns to be raised. This is available so that employees who feel they are not able to raise concerns internally have a method to do so in confidence. We investigate every whistleblowing case thoroughly and seek to achieve a resolution as soon as practicable. 
• Diversity Policy.
• Respect Charter – In 2025, we launched our Respect Charter which outlines our commitment to a culture of respect and safety. There is a dedicated Respect support email address to escalate any concerns.
• Recruitment Appointment Guidelines.
• WeCare – Our Employee Assistance Programme provides an external and confidential support and advisory service on a range of issues. Advice can be provided by telephone, video call or face-to-face counselling. 
• Wellness Charter – Our culture promotes and actively supports the wellness of all of us, every day.  It includes our commitment to diversity and inclusion in line with our value of respect.
• Supplier Code of Conduct – Suppliers are required to confirm that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. 
• Sustainable Procurement Policy – Strives to gain supply chain transparency and source products, materials and services using credible and recognised sourcing and certification schemes, where available. It also aims to help us identify and address human rights abuses and labour exploitation in our supply chain.
• SUEZ Standard Terms and Conditions – Our standard terms and conditions have an anti-slavery clause to ensure suppliers, their subcontractors and suppliers, comply with all applicable anti-slavery and human trafficking laws, statues, regulations and codes including the Modern Slavery Act 2015. 
  

SUEZ works with over 3,600 suppliers. Our procurement team has been trained to identify potential risks in our supply chain and have introduced the necessary controls to mitigate the risk.

Our Supplier Code of Conduct, which all suppliers sign up to when being onboarded, includes a commitment for suppliers to adhere to all laws and regulations prohibiting human trafficking and forced or indentured labour, such as the Modern Slavery Act 2015. This includes the preparation and publishing of an annual statement where their turnover exceeds UK legislative thresholds. We expect suppliers to implement policies, practices, and due diligence checks to ensure that modern slavery, child labour and human trafficking are not taking place in their supply chain, or in any part of their business. 

As such, suppliers must:

• Comply with all applicable laws, codes, and regulations wherever they operate;
• Promptly notify SUEZ of any significant criminal or civil legal actions brought against them; and
• Promptly notify SUEZ of any fines or administrative sanctions brought against them which relate in any way to the requirements set out in the Supplier Code of Conduct.

We also include our anti-slavery policy in our onboarding information for all new suppliers to make them aware that there is no ambiguity in our position with regards to modern slavery.

To ensure compliance with our Supplier Code of Conduct and Sustainable Procurement Policy, we actively monitor and engage with our supply chain. This includes conducting regular audits, collaborating with suppliers to promote best practices and implementing reporting mechanisms to identify and address any issues. By maintaining transparency and fostering strong partnerships, we strive to uphold ethical standards and mitigate risks of labour exploitation or human rights abuses within our supply chain.

To strengthen ethical supply chain practices, SUEZ actively collaborates with suppliers through ongoing engagement, knowledge-sharing and support. This includes regular discussions in supplier relationship management meetings, where suppliers are encouraged to adopt best practices and address any identified risks.

The frequency of audits and supplier relationship management meetings is determined based on the contract type, risk value and supplier performance levels. Suppliers are assessed individually, with higher-risk contracts or poorly performing suppliers undergoing more frequent audits and reviews. Similarly, newly onboarded contracts may require closer monitoring during the initial phases to ensure compliance and service quality. In addition, we continuously adapt our engagement strategy based on the service levels received – for example, suppliers who underperform or those with new contracts may have more frequent reviews to address challenges proactively.

This robust dynamic approach not only ensures continuous monitoring and improvement, it also facilitates supplier development by identifying opportunities for enhanced transparency and responsible sourcing.

We have risk assessed our supply chain at a high level and identified that our agency suppliers and managed service providers are an area where there is a potential risk. As such, we include labour provider audits as a standard agenda item in supplier relationship management meetings with these suppliers. Both our suppliers of agency labour and managed services are members of the Slave-Free Alliance with Smart Solutions also being registered with the Gangmasters and Labour Abuse Authority (GLAA), Stronger Together and the Association of Labour Providers (ALP) and are pro-actively undertaking additional checks to ensure that no SUEZ recruits are being exploited by outside influences. For example, during our audit checks, our main labour suppliers perform numerous checks to ensure the resource being provided has been vetted and checked for risk of modern slavery. These checks include but are not limited to, checking there is no duplication of essential information, that charges are not being levied to the staff for PPE, recruitment fees or transport costs and that the registration process is undertaken correctly including right to work documents checked.

We have a vendor neutral agency staff supplier which is engaged by SUEZ to provide a managed service delivering temporary labour services to our sites. They undertake regular modern slavery audits with the panel of agencies who supply SUEZ. This is to effectively manage the risk to the organisation and ensure that no person employed by SUEZ under these services is being exploited. 

These audits investigate if each agency has in place all the various checks that may bring to light instances of modern slavery – for example, duplicate address checks, duplicate next of kin checks, duplicate bank accounts. They also ensure that each agency has a modern slavery policy, a whistleblowing policy and a fair recruitment policy amongst others. These audits are shared with SUEZ on a quarterly basis, with any issues raised and discussed, including any actions, outcomes, or concerns as well as positive areas of best practice. Where the agency audit highlights actions required from a panel member and the agency doesn’t remedy the situation within the given timescale, that agency is removed from the panel and no longer used by our supplier or SUEZ.

We have improved our modern slavery questionnaires and assessment processes that are used when onboarding suppliers and in tenders as well as in Supplier Relationship Management meetings.

We have identified five classification areas that we believe are high risk within the UK. This classification has been done in conjunction with Slave-Free Alliance and focuses on sectors where vulnerable groups to modern slavery have been identified:

• Agency labour
• Construction
• Facilities management
• Industrial services
• Disposal

We renewed our membership with Slave-Free Alliance at the end of 2025, for another three years, demonstrating our continued commitment to managing the risk and taking steps to prevent modern slavery. Being a member of Slave-Free Alliance provides us with access to expertise and advice on best practice.

Our Optimisation Committee (Executive Team) receives updates twice a year on the work and progress of the modern slavery working party. These updates include seeking approval of actions and answering questions on the activities of the working party. The working party meets on a regular basis to identify and address risks, working closely with Slave-Free Alliance.

Data checks

Whilst we continue to check on duplicate addresses, bank details, next of kin and phone numbers,      we have not identified any red flags.

Training and building capacity

All new graded employees attend a full week’s induction which includes protected time for them to complete the online learning about modern slavery – including a test to ensure they have completed and learnt from the experience. All new frontline employees receive information on modern slavery and an information video to watch. Managers of frontline employees receive training on how to effectively deliver a modern slavery huddle card training session. The huddle card session contains the relevant learning for all our frontline employees.

Our Risk and Audit team carries out site checks on training completion.

Collaboration and partnerships

We recognise that no organisation can tackle the issue of modern slavery alone. We have sought to collaborate with others, share our own experiences and welcome learning best practice from others.

Slave-Free Alliance

We work closely with Slave-Free Alliance to address any risks and areas of improvement identified in the continuous improvement audit. We have created a joint action plan with clear priorities with Slave-Free Alliance which is reviewed regularly.    

Supply Chain Sustainability School

We are a partner of the Supply Chain Sustainability School (SCSS), an invaluable source of innovative learning content for anybody who works, or aspires to work, in the built environment industry. This content includes modern slavery resources and enables us to improve the training of our own employees. 

In addition, by joining the modern slavery leadership group for the school, we engage with other companies to share best practice on modern slavery and can input to future modern slavery resources. We are also able to direct our own suppliers in high-risk areas to access the free training on modern slavery provided by the school, a particular help to small and medium-sized suppliers that may not have their own resources. 

We are active members of the Supply Chain Sustainability School’s Modern Slavery Leadership Working Group and will be hosting a modern slavery training event for SMEs in Manchester as part of the drive to take this initiative to SMEs across the country.   

Waste & Recycling Modern Slavery Working Group

SUEZ was a founding member of this collaborative group across the sector. The Waste & Recycling Modern Slavery Working Group has 18 member businesses which span contracting, management, logistics, exporting of waste, textiles, paper, plastic, e-waste, metals and more. It raises awareness of modern slavery and develops solutions for mitigating the risks that the whole sector faces.

• Developed a supplier compliance verification programme to ensure supplier responses to standards, terms and conditions are validated.
• Expanded our modern slavery working party to include members of the SUEZ Works Council.
• Published our modern slavery reporting mechanism – including a flow chart with escalation process and a single point of contact – along with supporting guidance.
• Removed a potential temporary labour supplier from our supply chain after identifying concerns with their rates of pay.
• Organised training for the Senior Leadership team.
  

Our supply chain targets for 2026/27 are:

• To continue to improve the rigour of the modern slavery assessments in the onboarding process.

• We have classified the high-risk categories of spend which are: ­

• Agency Labour ­

• Construction ­

• Facilities Management ­

• Industrial Services ­

• Disposal

• We have worked with Slave-Free Alliance to identify appropriate mitigations for the suppliers within these categories in order to reduce the risk. We are implementing these mitigations and are continuing to issue questionnaires to high-risk suppliers in 2026/27. We will assess the results to identify any suppliers that are not meeting our standards and work with these suppliers to improve their performance or remove them from our supply chain.

• We are introducing specific contractual clauses for our high-risk suppliers which will be included in new contracts.

• Determine the levels and areas of training provided to indirect employees, such as agency workers, when their agencies onboard them.
• Work with Slave-Free Alliance to update and refresh our training session for all new employees.
• Work with Slave-Free Alliance to deliver bespoke refresher training for key stakeholders.
• Develop a digital learning package for frontline employees.
• Deliver dedicated information webinars through our wellness and inclusion programme.

This statement has been approved by the board of SUEZ Recycling and Recovery UK Ltd on 17 June 2026 who will review and update it annually.

John Scanlon, Chief Executive Officer, SUEZ Recycling and Recovery UK Ltd