modern slavery policy

Our Policy

1. Purpose

This policy outlines Evolve’s commitment to identifying, preventing, and addressing modern slavery and human trafficking in all areas of our business operations and supply chains. We recognise our responsibility under the Modern Slavery Act 2015 and are committed to taking a robust, proactive approach to ensuring our business and supply chain remain free from all forms of modern slavery.


Modern slavery includes, but is not limited to, forced labour, human trafficking, debt bondage, servitude, and exploitation. We acknowledge that such abuses can occur in any industry and country, and we are committed to operating in a manner that respects human rights and dignity.


2. Scope

This policy applies to all employees, contractors, freelancers, suppliers, service providers, and 

partners working with or on behalf of Evolve across all global operations.


3. Our Commitment

We are committed to:

• Upholding the principles of the Modern Slavery Act 2015

• Conducting our business with zero tolerance for any form of modern slavery or human 

trafficking

• Embedding ethical labour practices across our internal operations and external supply 

chains

• Building awareness and capability among staff and suppliers to identify and address 

potential risks

• Engaging with suppliers and partners to improve transparency and encourage responsible 

business practices


4. Supply Chain Management

Our supply chain is global and diverse, including design, production, logistics, materials, and 

service providers. To manage the risk of modern slavery:

• All new suppliers must comply with our Supplier Code of Conduct, which includes modern 

slavery and human rights standards.

• Contracts with suppliers and subcontractors will include specific clauses requiring 

compliance with anti-slavery obligations.


5. Actions Taken to Date

To support our commitment, we have already undertaken the following steps:

• Launched mandatory training for all staff on recognising and reporting signs of modern 

slavery.

• Introduced a Public Interest Disclosure (Whistleblowing) policy in our Employee Handbook, 

enabling employees and partners to report concerns confidentially and without fear of 

reprisal.



6. Future Actions and Targets

We recognise there is more to do and commit to the

  • Ensure all Tier 1 suppliers acknowledge and 
  • comply with our modern slavery policy.
  • Maintain Staff Awareness
  • Formalise Due Diligence

  • Distributed our Code of Conduct to all Tier 1 suppliers.
  • Request a formal sign off creating adocumented trail of due diligence
  • Ensure training to all new starters and existing staff
  • Implement pre-qualification modern slavery checks for new suppliers


Ongoing

Head of Process & Compliance

  • 100% Tier 1 suppliers reviewed
  • 100% staff trained
  • System embedded in onboarding

7. Reporting and Whistleblowing

We encourage anyone working for or with Evolve to raise concerns about suspected modern 

slavery or unethical practices. Reports can be made confidentially to our Operations Director, as 

per the Public Interest Disclosure section within our Employee Handbook.

All reports are investigated by the Operations Director and appropriate action is taken in line with 

our disciplinary procedures and legal obligations.


8. Accountability and Review

Responsibility for this policy lies with senior management and is implemented by the Head of 

Process and Compliance. This policy is reviewed annually to ensure its relevance, effectiveness, 

and compliance with current legislation.


9. Endorsement

This Modern Slavery Policy has been reviewed and approved by the Managing Director. It reflects 

our commitment to ethical conduct and transparency across all business practices.