Modern Slavery & Human Trafficking Policy

This statement sets out Capital's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its business and its supply chains.

As a responsible company Capital recognises that it must take a robust approach to slavery and human trafficking. Capital is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

Structure & Supply Chain

This statement covers the activities of Capital Cleaning (Kent) Limited:

Capital sells cleaning and hygiene products, equipment, machinery, workwear and PPE. It also offers associated washroom services and machine repairs. Work is carried on at its premises in Aylesford and deliveries are made using our own vehicles and courier services. Repairs and provided services are carried out at clients premises.

We have a large number of contracted and non contracted suppliers.

Assessment process:

Company assessment is carried out on an annual basis according to government guidelines.

Purchasing staff are obliged to follow the risk analysis process when identifying new suppliers.

Suppliers are risk assessed and high risk suppliers audited.

Areas of risk:

There are currently no areas of high risk.


Responsibility for anti slavery issues are with:

Policies. The MD will draft and ensure implementation of all policies and procedures.

Review. The MD will carry out a review at least annually.

Risk Assessment. The Purchasing Director will carry out supplier risk assessments and the MD will carry out internal risk assessment.

Due Diligence. The office manager will sign off all activities.

Training. The induction process will cover this topic and it will be reviewed annually as part of the appraisal process.

Policies & Conduct

Capital operates the following policies all of which are designed to help prevent any slavery and human trafficking as a result of its operations.

  • Whistle Blower Policy
  • Staff Code of Conduct
  • Supplier Code of Conduct
  • Anti-Bribery & Corruption Policy
  • Due Diligence

Capital staff follow due diligence guide lines when considering new suppliers and regularly review existing suppliers. Our due diligence and review processes include:

Mapping the supply chain broadly to assess particular product or geographical risks of slavery and human trafficking.

Evaluating the slavery and human trafficking risks of each new supplier.

Reviewing on a regular basis all aspects of the supply chain based upon the supply chain mapping.

Conducting supplier audits or assessments by Capital which have a greater degree of emphasis on slavery and human trafficking where risks are identified.

Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct; including the possible termination of business relations.

Performance Indicators

Capital has reviewed its KPI's in light of the introduction of the Modern Slavery Act 2015. As a result Capital:

Requires all staff to have the relevant training.

Follow the system for verification of potential new suppliers.

Follow the system for on-going evaluation of existing suppliers.


The training undertaken by all relevant staff has been formulated using the guidelines of the Stronger Together initiative.


This statement is written and approved by the board of Capital and updated on an annual basis.

Stephen Wentzell