Hatton Traffic Management have a zero-tolerance approach to modern slavery

Hatton Traffic Management Limited is committed to preventing modern slavery and human trafficking in all aspects of our operations and supply chain. 

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. 

Hatton Traffic Management Limited has a zero-tolerance approach to modern slavery and human trafficking, and we are committed to acting ethically and with integrity in all our business dealings and relationships. We implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 

We conduct our business in a manner that ensures the absence of modern slavery practices. Our recruitment and employment practices are designed to ensure all employees are legally entitled to work and are treated fairly. We do not tolerate forced labour, bonded labour, involuntary prison labour, slavery or human trafficking. 

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. 

We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We also expect that our suppliers will hold their own suppliers to the same high standards. 

We take the following steps to prevent modern slavery: 

  • Only engage with reputable suppliers and subcontractors who demonstrate ethical practices. 
  • Include anti-slavery clauses in supplier contracts. 
  • Monitor labour standards compliance within our supply chain. 
  • Provide awareness training to relevant staff to recognise signs of modern slavery. 

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. 

This policy does not form part of any employee’s contract of employment, and we may amend it at any time. 

We encourage all employees and contractors to report any concerns regarding modern slavery or human trafficking. All reports will be fully investigated, and appropriate action taken.

RESPONSIBILITY

The director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.  

The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.  

Line managers at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.  

Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the HR Officer. 

ORGANISATION STRUCTURE, BUSINESS AND SUPPLY CHAIN

Hatton is a privately owned UK company providing traffic management services and installation/repair of vehicle restraint systems across the UK. Our operational depots are located in Aberdeen, Newcastle, Oldham, Doncaster, Amersham, Wembley, Tottenham and Chelmsford, and our work covers NHSS scopes Type 2A, 2C, 10B, 12AB, 12C and 12D. 

Our organisational structure comprises central functions including Commercial, Finance, Transport, QHSE, Technical, Systems and HR, alongside regional operational divisions across Scotland, North & Central England, South England, Greater London, Events, and Civils, as shown in the IMS Organogram. 

Our supply chain includes: 

  • Traffic management equipment providers
  • PPE and consumables suppliers
  • Subcontractors providing labour, civils works, fencing and vehicle restraint activities
  • Specialist training organisations
  • Fleet and plant suppliers

We engage both UK-based and international suppliers, although the majority of our supply chain is UK-based. We work only with reputable and pre-approved suppliers who can evidence compliance with UK employment, human rights and ethical trading standards. 

DUE DILIGENCE

Hatton operates formalised due diligence processes aligned with our Integrated Management System and procurement controls. These include: 

  • Supplier evaluation and re-evaluation: All suppliers and subcontractors are assessed against compliance, capability, quality and ethical criteria during onboarding and periodically thereafter 
  • Contractual controls: All supplier contracts include anti-slavery clauses prohibiting forced, bonded or trafficked labour and requiring compliance with the Modern Slavery Act.
  • Risk assessment: We consider geographic, sector and labour-related risk indicators when appointing new suppliers, informed by our IMS risk and opportunities procedures (C/5)
  • Ongoing monitoring: We monitor supplier performance using audits, quality checks, site inspections and performance reviews, as set out in our IMS performance evaluation process (C/15) 
  • Incident reporting: Any concerns regarding unethical behaviour, labour exploitation or suspected modern slavery can be raised through our Whistleblowing Policy and handled in accordance with our Non-Conformity & Corrective Action Procedure (C/18) 

These processes help us identify, prevent and respond to any risks of modern slavery or unethical labour practices. 

AREAS OF RISK AND MITIGATION

We recognise that certain parts of our business and supply chain may present a higher risk of modern slavery. These include: 

  • Subcontracted labour or temporary labour providers
  • Suppliers of PPE, signage or equipment sourced internationally
  • Lower-skilled roles where exploitation risk may be higher
  • Transport, logistics and vehicle-related supply chains

To assess and manage these risks, Hatton implements the following steps: 

  • Risk identification: Using our IMS hazard and risk methodology (including OP002 and risk mapping under C/5) we periodically review our supply chain and business activities for modern slavery indicators.
  • Supplier categorisation: Suppliers are assigned a risk level based on country of origin, type of labour used, sector and previous performance.
  • Enhanced checks: Higher-risk suppliers undergo deeper due diligence, including declarations, audits, compliance checks and, where applicable, evidence of employment practices.
  • Ongoing assurance: Through audits, supplier meetings, site inspections and performance monitoring, we ensure continued compliance with ethical labour standards.
  • Employee vigilance: Staff are trained to identify warning signs of labour exploitation and report concerns immediately.

EFFECTIVENESS INDICATORS

Hatton monitors the effectiveness of our approach to preventing modern slavery by reviewing performance indicators aligned with our IMS performance evaluation processes (C/15)  

These include: 

  • Number of supplier audits completed and percentage meeting ethical compliance standards
  • Percentage of suppliers with active anti-slavery clauses in place
  • Proportion of suppliers re-evaluated annually 
  • Number of staff trained on modern slavery awareness
  • Number of reported concerns, incidents or whistleblowing cases relating to labour exploitation
  • Time taken to investigate and close any concerns raised
  • Findings from internal audits, management reviews and site inspections
  • Corrective actions raised and resolved relating to supply chain or labour issues

These metrics are reviewed during periodic management reviews to drive continual improvement. 

COMPLIANCE

All employees are required to read, understand and comply with this policy.  

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.  

Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.  

Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.  

If an employee believes or suspects a breach of this policy has occurred or that it may occur, they must notify their Line Manager or HR Officer to report it in accordance with our Whistleblowing Policy as soon as possible.  

If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise it with their Line Manager or HR Officer.  

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform the Commercial Manager immediately. If the matter is not remedied, and they are an employee, the employee should raise it formally using our Grievance Procedure. 

COMMUNICATION & AWARENESS

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary through the Supply Chain School of Sustainability.  

Our zero-tolerance approach to modern slavery must be communicated to all suppliers and subcontractors at the outset of our business relationship with them and reinforced as appropriate thereafter. 

BREACHES

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.  

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.   

Ref: PY020-CEN Rev 4.0 – 08/10/2025