Anti-Slavery and Human Trafficking Policy

Policy Statement:

This policy applies to all person working for us or on behalf of us in any capacity, including any employees at all levels, Directors, Officers Agency Workers, Second Workers, Volunteers, Agents, Contractors and Suppliers.

3WAY Group. Strictly prohibits the use of modern slavery and human trafficking, in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organization or in any of supply chain. We expect that our suppliers will hold down their own suppliers to the same high standards.

Modern slavery is a term used to encompass slavery, servitude, forced or compulsory labour, bonded or child labour and human trafficking. Human trafficking is where a person arranges or facilities the travel or another person with a view to that person being exploited. Modern slavery is a crime and a volition of fundamental human rights


We shall be the company that expects everyone working with us to or on our behalf to support and uphold the following measures to safeguard against modern slavery.

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains
  • The prevention and detection and reporting of modern slavery, in any part of our organization or supply chain is the responsibility of all those working on our behalf. Workers must not engage in, facilitate, or fail to report any activity that may lead to, suggest or breach this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk with modern slavery in our operations and supply chain
  • We take a risk-based approach to our contracting processes to help keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour with our contracts with third parties. Using our risked approach, we will also assess the merits of writing to suppliers requiring them to comply with our code of conduct, which sets the minimum standard required to combat modern slavery and trafficking
  • Consistent with the risk-based approach we may require employment and requirement agencies and other third parties supplying workers to our organization to confirm their compliance with our code of conduct
  • Suppliers engaging workers through a third parties to obtain that third parties’ agreement to adhere to the code
  • As part of our ongoing risk assessment and due diligence process we will whether circumstances warrant us carrying out audits and suppliers for their complaint of code of conduct
  • If we find that any other individual or organizations working on our behalf have breached our policy, we will ensure that we take the appropriate action. This may range from considering the possibly of breeches being remediated and whether that may represent the best outcome for those individuals impacted by the breech to terminating such relationships


Date: 16.03.2024

Next Review Date: 15.03.2025


Signed: R Poole

Signed: R A M Poole

Managing Director


Mr Richard Poole

Mr Richard Anthony Mark Poole

Chief Executive Officer