Modern Slavery and Human Trafficking Policy
Purpose and scope
Nexus Mechanical Electrical Renewables Ltd is committed to preventing modern slavery and human trafficking in its operations and supply chains. This policy applies to directors, employees, temporary workers, agency workers and anyone working on our behalf. We expect suppliers and subcontractors to follow equivalent standards.
Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. Exploitation can occur in recruitment, employment, accommodation, transport and the manufacture or supply of products.
Our commitments
We will not knowingly use or benefit from forced labour, trafficked labour or child labour. People must be free to leave employment in accordance with their contract and the law. We do not permit retention of passports or identity documents as a condition of work, threats or intimidation, unlawful deductions from pay, or recruitment fees charged to workers for obtaining a job with us.
We provide clear terms of work, pay workers lawfully, check the right to work where required, and treat workers with dignity. Concerns may be raised without retaliation.
Risks in our work and supply chain
Our activities include mechanical, electrical and renewable energy installations, maintenance and associated procurement. Potential areas of exposure include labour supplied through agencies or subcontractors, work on construction sites, and the manufacture and distribution of solar panels, batteries, electrical equipment and other components. We assess risk according to the work, the recruitment route, the location and nature of the supplier, and any warning signs.
We recognise that the solar supply chain carries a particular risk: a large share of solar-grade polysilicon and wafers has been linked to state-imposed forced labour in the Xinjiang Uyghur Autonomous Region of China, and upstream supply chains for panels and batteries are often complex and hard to trace.
Recruitment and supplier checks
Before engaging workers, agencies or subcontractors, we confirm their identity and relevant right to work, obtain clear contractual terms and verify who employs and pays the workers. We ask agencies and subcontractors to confirm that they prohibit forced labour, worker-paid recruitment fees and retention of identity documents.
For suppliers presenting greater risk, we seek proportionate information on labour practices, recruitment, subcontracting and corrective actions. We may request evidence, meet workers or inspect relevant records where appropriate and lawful. Contracts and purchase terms should require suppliers to comply with applicable modern slavery laws, raise concerns promptly and cooperate with reasonable enquiries. We record checks and follow up material concerns.
For solar panels, batteries and inverters, we will favour suppliers that can provide traceability or origin information for key components, or hold recognised independent certification (such as Solar Stewardship Initiative standards), and we will avoid products where credible evidence links them to forced labour.
Recognising and reporting concerns
Warning signs may include workers appearing fearful, unable to speak freely, lacking control of their identity documents or wages, being transported and housed under coercive conditions, or saying that they paid a fee to secure work. A warning sign is a reason to enquire safely, not proof of exploitation.
Anyone with a concern should promptly tell their line manager or a Nexus director, or contact Richard Del Strother (richard@nexusmer.co.uk). If that person is involved, report to another director. Do not confront a suspected exploiter or put a potential victim at further risk.
In an immediate emergency call 999. For a non-emergency police report call 101, or contact the UK Modern Slavery and Exploitation Helpline on 08000 121 700.
Response and protection
A director will assess and document a report promptly, protect the person affected, keep information confidential as far as practicable, and seek specialist or police advice where appropriate. We will consider the wishes and safety of a potential victim before taking action, subject to legal duties and immediate safety needs. We will not penalise anyone for raising a genuine concern in good faith.
Where a concern involves a supplier or subcontractor, we will investigate and require corrective action when appropriate. We may suspend or end the relationship if the risk cannot be addressed. We will avoid action that unnecessarily harms affected workers, and will keep a record of the decision and follow-up.
Responsibility and review
The directors are responsible for implementing this policy, allocating responsibility for supplier checks and ensuring relevant staff know how to identify and escalate concerns. Managers must apply the policy in recruitment and procurement.
Staff involved in recruitment, procurement and site supervision will receive modern slavery awareness training on induction and refresher training at appropriate intervals, and we will keep a record of training completed. Everyone working for Nexus must report concerns.
We will review this policy at least annually and after a significant incident or change in our activities. We will consider whether staff awareness, supplier checks, reports and corrective actions show that the controls are working. This policy is distinct from any annual slavery and human trafficking statement that may be required under section 54 of the Modern Slavery Act 2015 if the applicable statutory criteria are met.
In reviewing this policy we will have regard to current Home Office statutory guidance, Transparency in supply chains: a practical guide (March 2025).
Approved by: Steve Clark · Date: 1 September 2026