This statement sets out the steps taken by Panthera Group Ltd. to prevent modern slavery and human trafficking in its business and supply chains.

This statement has been approved by the Directors of the Company and signed by the MD, Neal James.,

Modern slavery encompasses slavery, servitude, human trafficking and forced labour, Panthera Group Ltd has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.


1. Business, structure and supply chains

Panthera Group Ltd (known as Panther Group) and Panthera Security Ltd are owned by Panthera Group Holdings Ltd., and operate in the construction sector, supplying security, hoarding and temporary site set-up services to construction companies, mainly in London and the Home Counties. Although we have no international operations and a limited number of suppliers, a considerable proportion of our supplies come from abroad.

High risk areas

Supplies of timber are likely to be the area of most risk as the majority is imported; for that reason, we have a policy of using only FSC or PEFC timber from renewable resources with a Chain of Custody, and sourced from well-known, long term and trusted suppliers on our preferred supplier list.

We conduct due diligence on suppliers before allowing them to become a preferred supplier.  This due diligence includes the completion of our supplier questionnaire and an online search to ensure the organisation has never been convicted of offenses relating to modern slavery.  Our policy, forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

  1. they have taken steps to eradicate modern slavery within their business
  2. they hold their own suppliers to account over modern slavery
  3. for UK based suppliers, they pay their employees at least the national minimum wage / national living wage (as appropriate)
  4. that they understand that we may terminate the contract at any time should any instances of modern slavery come to light.


2. Modern slavery and human trafficking policies

Our policies

We operate a number of internal policies and procedures to ensure that we are conducting business in an ethical and transparent manner. These include:

  1. a robust recruitment policy, including conducting eligibility to work in the UK, and checks for all employees to safeguard against human trafficking, child labour or individuals being forced to work against their will.
  2. An Equality & Diversity Policy, which conforms to the Equality Act 2010, by ensuring equal opportunities for all workers, job applicants, visitors, clients and customers.
  3. adherence to international and local labour laws and standards, and adherence to the ETI base code.
  4. a Code of Conduct policy which explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
  5. all employees are registered with Citation, our HR advisors.


We conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.


3. Risk Assessment, prevention and mitigation

Whilst we are aware of the risks of modern slavery, and know from the ITUC Human Rights Index and the Global Slavery Index, the countries and regions where it is mainly found, it is extremely difficult for a small company like ours, to take any steps that could make significant changes.

One thing we are able to do, is to support larger companies and organisations, such as FSC & PEFC and Tier 1 building contractors, in the hope that with our help, they will be able to make a difference.


4. Due Diligence Processes

While we are able to monitor our immediate supply chain, it is difficult for a small business to monitor or have any effect on our extended supply chain, particularly from suppliers overseas.

However, because we are a SME, we are able to be confident that there is no modern slavery in our company or in our operations, as all of our workers are personally known to the management and Directors.

Further more they have all signed a contract and are given an employee handbook and access to all company policies on appointment.

Our suppliers are requested to complete a questionnaire annually, asking for details of their Modern Slavery experience and requesting evidence of any programmes or initiatives undertaken to manage and mitigate modern slavery risk.

If case of modern slavery was discovered or suspected, we would make further enquiries if possible, and report it to the Modern Slavery helpline, on 08000 121 700 or the police on 101.


5. Effectiveness, measured against appropriate KPIs

Our performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
  • We will continue to monitor our own performance and that of our suppliers.
  • Right to work checks on new employees and sub-contractors will be carried out rigorously to ensure we are employing people legally.
  • Support and access to Modern Slavery training will be given to all managers.


6. Training

  • Training access and support, will be given to senior management, estimating and buying teams, and labour management.
  • Training will include an elearning module, from Citation’s Atlas portal.
  • A report, Building a Fairer System, by the Chartered Institute of Building, has been distributed to teams and management.
  • All operatives concerned will subscribe to the Ethical Trading Initiative, and receive regular news and updates.


Name: Neal James

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Date: 01/01/2024