Modern Slavery and Human Trafficking Policy


The Modern Slavery Act is a globally leading piece of legislation. It sets out a range of measures on how modern slavery and human trafficking should be dealt with in the UK. Whilst not all of the Act is directly relevant for business, section 54 entitled ‘Transparency in supply chains’ impacts the corporate sector. The Act, which came into force on 29th October 2015.


The purpose of this policy is to outline Appsbroker’s response to the requirements of the Modern Slavery Act 2015 and the role you can play in combating modern slavery and human trafficking in order that offenders may be prosecuted and victims safeguarded.

Nature of Threat

Although it is impossible to know exact numbers of victims, we do know that modern slavery is on the increase.  Many victims work in the construction industry, in agriculture, in the sex industry, and in places like nail bars, car washes, and cannibis farms.  Children are working in all of these situations, as in sexual slavery.

Many victims have been trafficked from overseas – frequently from eastern Europe, south east Asia, and Africa – and their exploitation often begins en route.  British victims tend to have fallen on difficult times, making them vulnerable to the lure of well-paid work complete with decent accommodation, which proves a cruel lie. 

Most victims are ‘recruited’ in person, although some who find themselves trapped in the sex industry have been ensnared through online job adverts and social media websites. In cases of sexual exploitation, adult services websites often unwittingly play a key role in expanding offenders’ client bases.

In some cases victims are threatened and can suffer extreme violence as the criminals exert control. Many have their identity documents confiscated and have most of their earnings withheld as ‘payment’ for living costs or for their journey to the UK.

Although some larger organised crime groups are involved, people are also trafficked by looser collaborating networks often involved in additional forms of serious criminality, including drugs and firearms trafficking.

Policy Statement

Modern slavery is a crime and violation of fundamental human rights.  It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain. 

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards. 

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, employees, contractors, third-party representatives and business partners.

Know the Signs

There are often indicators or “signs” associated with modern slavery.  The following is a list of possible “signs” that may arise during the course of you working for us and which may raise concerns under the Modern Slavery Act. The list is not intended to be exhaustive and is for illustrative purposes only. If you encounter any of these “signs” while working for us, you must report them promptly to your line manager or our Finance Director.   

  • Unusual travel times. Individuals may be dropped off/collected for work on a regular basis either very early or late at night
  • Restricted freedom of movement.  Individuals may have little or no opportunity to move freely.
  • Living conditions.  Individuals may sleep on the floor, live in unsuitable conditions and/or be forced to live and work in the same location. They may suffer physical or verabuse from the ‘employer’.
  • Few or no personal belongings. They may wear the same clothes and have little or no personal belongings.
  • Inappropriate clothing for work.  Individuals may not be wearing suitable clothing for their work.
  • Physical appearance.  They may also show signs of physical or psychological abuse, look malnourished, unkempt, or appear withdrawn.
  • Isolation.  Individuals may rarely be allowed to travel on their own and seem under the control of others.
  • Fear.  They may rarely interact, seem anxious or afraid.

Roles and Responsibilities

The Finance Director, as the procurement lead,  has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it Financial Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.

You must ensure that you read, understand and comply with  this policy.  The prevention, detection and reporting of modern slavery and human traffiking are the responsibility of all those working for Appsbroker. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible, if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.  Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. We reserve the right to terminate our contractual relationship with other workers if they breach this policy.

Annual Reporting

In line with the Modern Slavery Act requirements Appsbroker will publish an annual modern slavery act statement in its audited accounts. This statement will be available on the website, and will outline the steps it takes to prevent modern slavery within company business and supply chains.

Anti-slavery and Human Trafficking Report – July 2023

What to do if you become aware of violations

You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. It is important that you tell your line manager, Finance Director or  email [email protected] as soon as possible if you have any occasions of suspected or known contraventions to this policy.  You are encouraged to raise concerns about any issue or suspicion at the earliest possible stage. If you are unsure whether a particular act constitutes modern slavery, or if you have any other queries or concerns, these should be raised with your line manager OR email [email protected].  In the event that you do not feel able to speak to anyone at Appsbroker, or because your suspicion does not relate to Appsbroker, its operations, customers or supply chain you should call the Modern Slavery Helpline on 08000 121 700.

Training and Awareness

This policy forms part of our induction to ensure  all new employees are informed from day one in the business. All employees will receive regular, relevant training on how to implement and adhere to this policy. 

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. In addition we may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Monitoring & Review

The Finance Director will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in counteringmodern slavery and human trafficking. 

All employees are responsible for the implementation of this policy and should ensure they use it to disclose any concerns in this regard.. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to [email protected]. This policy does not form part of any employee’s contract of employment and it may be amended at any time.

Revised: 27/06/2022