Modern Slavery Statement




This statement is made on behalf of Whittan Industrial Ltd and Apex Space Solutions Ltd. It is a statement made in accordance with section 54 of the Modern Slavery Act 2015 and covers the 2018-19 Financial Year.

Our approach to tackling modern slavery is influenced by our values, in all our dealings with customers, business partners, colleagues and each-other. Both Whittan Industrial Ltd and Apex Space Solutions Ltd strive to operate with integrity and we recognise our responsibility to be aware of the risks of modern slavery and human trafficking within our own Group and supply chain.

About Us

Whittan Industrial Ltd has 3 core sites in the UK. We employ around 400 staff members undertaking a range of roles including Fulfilment, Sales, Manufacturing, Technical, Finance, IT, HR and business strategy. Apex Space Solutions Ltd has 1 site in the UK where we employ around 235 staff who undertake roles within Fulfilment, Sales, Manufacturing, Technical, Finance, IT and HR.

We use agency labour in our manufacturing areas which is sourced through reputable recruitment agencies and the individuals work alongside our core employee population. We also have third party contractors working on site who provide specialist expertise in areas such as installation. We outsource certain services for a number of activities such as logistics and cleaning. Appropriate right-to-work checks are conducted in partnership with those agencies.

Within our direct supply chain, there are around 40 different raw material suppliers. Our indirect supply chain currently consists of over 400 active suppliers.

We have carried out a desktop review of our direct supply chain and have concluded that the risks of modern slavery and human trafficking are low. However, we acknowledge that we must remain vigilant to the risks and ensure that our suppliers understand and play their part in ensuring that modern slavery and human trafficking does not take place in our organisation or supply chains. This message will be reiterated to our suppliers via our procurement teams in each supplier review. To find out more about what we do, please go to

Relevant policies and contracts

To reinforce our commitment to combating slavery and trafficking, we have implemented the following policies, which set out our zero-tolerance approach to modern slavery, both within our own operations and our supply chain:

(a) We have published guidance to our employees through our internal Anti-Slavery & Human Trafficking Policy, Code of Conduct and Bribery & Corruption Policy which apply to all those working for us or on our behalf.

(b) We have reviewed our existing policies and have made amendments to recognise our obligations under the Act including our Whistleblowing Policy which enables employees to raise concerns through our transparent and accessible reporting process. This provides support to our employees in making day to day ethical decisions in addition to the specific Anti-Slavery & Human Trafficking Policy already in place.

(c) We have in place a Supplier Assessment Questionnaire which includes a specific section of ethical trading and applies to all existing suppliers in our supply chain. This checklist asks suppliers to confirm they have a stance on modern slavery. In order to improve our processes we have introduced a new software system which will ensure consistency of data collection and monitoring as well as acting as a central repository for the information.

(d) We are reviewing the steps we take when engaging with new suppliers, contractors and business partners to ensure that they are aware of and will adhere to our Procurement Standards & Supplier Requirements Policy which will be launched later this year. These updated processes will allow our procurement team to assess the likelihood of modern slavery or trafficking existing in those organisations and understand what measures are already in place to combat those risks.

Risk assessment processes

We have considered the risk of modern slavery in our own operations and we have concluded that, on the basis that we are a UK/EU employer subject to UK/EU employment protections and practices and already have well developed checks and balances within our business, we have a low risk of modern slavery occurring in our own operations. One such check is that of employee bank and home address data which is reviewed regularly to highlight anomalies such as multiple employees with the same data.


Our suppliers who fall into the following categories will be encouraged strongly to commit and adhere to the emerging revision to Whittan standards, which include;

  • Suppliers of raw materials
  • Those involved in the manufacturing of our bought-in products
  • Those providers of services supporting the delivery of our overall customer offering

We have considered the risk of modern slavery occurring in our use of external labour via employment agencies. Given the organisations that we work with and the existing checks that we apply in these areas, we have concluded that the risks of modern slavery are low in this area.

We have also concluded, however, that we would benefit from a higher degree of oversight in relation to our direct suppliers and this is an area of focus that we have identified going forward into our next financial year. As mentioned above, this links to the sourcing of a new software package to support internal processes and data management.

Due diligence processes

In order to prevent slavery and trafficking in our business and supply chains, we are taking steps to update and improve our supplier due diligence process, particularly in the case of our direct suppliers and any supplier not yet subject to the Supplier Assessment Questionnaire. We are taking the following steps in relation to our supply chain:-

Reviewing those in our supply chain where modern slavery risks are deemed higher, in order to:

  • set out our zero-tolerance approach to modern slavery;
  • require them to confirm that they will adhere to the principles set out in our Procurement Standard & Supplier Requirements policy once completed;

We shall review the responses from our suppliers to judge future actions and assess what further due diligence is required.


To raise awareness of modern slavery and trafficking, and to point staff to how our policies and procedures support organisational diligence and compliance; we have trained salaried employees in this compliance area. Our hourly-paid colleagues will be trained in the coming months. All compliance modules will be set up so that they are completed by each employee on an annual basis.

We have dedicated e-learning modules covering other key compliance areas such as Bribery & Corruption, GDPR, Diversity & Inclusion; which are compulsory courses for all staff.

Measuring effectiveness – performance indicators

In order to monitor the effectiveness of the steps we have taken to stop slavery and trafficking taking place in our business and supply chains, we will use the following performance indicators for the financial year ahead:

  • All employees will have completed the relevant training, as referenced above
  • We will have reviewed and re-issued our Anti-Slavery & Human Trafficking, Whistleblowing and Code of Conduct policies to our workforce setting out our stance in relation to modern slavery and will reinforce key messages throughout the year through the use of poster campaigns, formal and informal communication channels
  • We will establish a process to gain a better oversight of our direct supply chain and consider how best to improve risk assessments, carry out due diligence and communicate with these suppliers in relation to Modern Slavery and Human Trafficking issues
  • Our commodity buyers will have completed the CIPS ethical accreditation training module

We will ensure that we continue to refresh and revise our Anti-Slavery and Human Trafficking clauses in our contracts with our suppliers.

As we develop our risk assessment and due diligence processes, we will assess and consider the appropriateness of developing further measures, we will monitor the need for further action to be taken and other key performance indicators to be implemented.

This statement has been approved by the Whittan Board of Directors who will review and update it annually.


Signed on behalf of the Board of Directors by Toni Newcombe on 28 March 2019