Modern Slavery and Human Trafficking Policy

1. Purpose

HJ Wheeler Associates Ltd is committed to preventing modern slavery, human trafficking, slavery, servitude and forced or compulsory labour within our own activities and supply chains. We act ethically and with integrity and expect those we work with to do the same.

This policy reflects the principles of the Modern Slavery Act 2015 and our commitment to taking a proportionate, risk-based approach to identifying and managing modern slavery risk. Although HJ Wheeler Associates Ltd is not required to publish a statutory modern slavery statement under section 54 of the Act, we recognise the importance of these responsibilities when working with public, voluntary and private sector organisations.

2. Scope and Our Business

HJ Wheeler Associates Ltd is a small UK-based leadership, coaching and organisational development consultancy. Services are delivered by the Director and a network of independent professional associates.

Our direct supply chain is relatively limited and principally includes professional associates and specialist partners, venues and hospitality, travel and accommodation, IT and technology services, office supplies and other professional services.

This policy applies to the Director, any employees or workers where applicable, contractors and associates engaged by HJ Wheeler Associates Ltd, and to suppliers, partners and third parties with whom we do business.

3. Our Commitment

We do not tolerate any form of modern slavery or human trafficking. We are committed to:

• staying alert to modern slavery risks within our own activities and supply chains;
• promoting fair, lawful and respectful working practices;
• contracting fairly and transparently with associates and professional partners;
• taking modern slavery risk into account when selecting or reviewing relevant suppliers and partners;
• taking concerns seriously and responding promptly and proportionately; and
• protecting the welfare of any person who may be at risk of exploitation.

4. Understanding and Assessing Risk

As a small professional services business, we assess the risk of modern slavery within our direct consultancy activity as relatively low. Our work is predominantly delivered in the UK by skilled independent professionals. We do not, however, assume that any supply chain is entirely without risk.
Risk may arise further down the supply chains that enable our work. We therefore pay particular attention, where relevant, to purchasing or services associated with hospitality and catering, hotels and accommodation, cleaning and facilities services, transport and logistics, IT hardware and electronics, and other goods sourced through complex or international supply chains.

We consider the nature of the product or service, the workforce involved, location and supply-chain complexity, and any other information that may indicate increased vulnerability to exploitation. Our attention and due diligence will be proportionate to the level of identified risk.

5. Associates, Suppliers and Due Diligence

We aim to work with associates, suppliers and partners that act ethically and responsibly. Our own arrangements with associates are intended to support fair professional relationships through clear terms, agreed rates and timely payment.

We take a proportionate and risk-based approach to supplier due diligence. Routine purchases from established UK professional suppliers will not normally require extensive checks. Where the nature of a supplier, product, service, location or supply chain indicates a higher risk, we may:

• seek information about employment and labour practices;
• review a supplier’s published modern slavery statement or relevant policies where available;
• seek information about relevant subcontractors or supply chains;
• ask for assurances or evidence of action to mitigate identified risks; and
• take modern slavery risk into account when deciding whether to enter into or continue a business relationship.

Where appropriate, we will cooperate with reasonable modern slavery due diligence or supply-chain information requirements made by public-sector clients in relation to contracts we deliver.

6. Responsible Purchasing

Price alone will not determine our choice of supplier where there is a meaningful ethical or labour risk. We will consider quality, value, social and environmental factors and modern slavery risk where these are relevant to the purchase.

We will be alerted to purchasing arrangements, unusually low prices or delivery expectations that could indicate or contribute to poor labour practices or worker exploitation.

7. Reporting Concerns

Anyone working with or supplying HJ Wheeler Associates Ltd who has a concern about possible modern slavery, human trafficking or labour exploitation connected with our activities or supply chains should raise it with the Director, Holly Wheeler, at hollywheeler@gmail.com.

Concerns will be taken seriously and handled as sensitively and confidentially as circumstances allow.

Anyone raising a genuine concern in good faith will be supported and will not be disadvantaged for doing so.

8. Responding Where Concerns Arise

Where a concern is identified, our first consideration will be the safety and welfare of any person who may be at risk. We will consider the circumstances, seek appropriate specialist or statutory advice where necessary and take proportionate action.

Depending on the circumstances, this may include seeking further information, agreeing or requiring corrective or remedial action, monitoring improvement, suspending a relationship, referring concerns to appropriate authorities or support organisations, or ending a supplier or partner relationship.

We recognise that automatically terminating a supplier relationship may not always be the best way to protect people at risk. Where it is safe and appropriate to do so, we will seek to support effective remediation. We reserve the right to suspend or terminate a relationship where concerns are serious, remain unresolved, or a supplier or partner is unwilling to take appropriate action.

9. Awareness and Responsibility

The Director has overall responsibility for this policy and for considering modern slavery risk in relevant supplier and partner decisions.

As a small business, we do not operate a formal organisation-wide training programme. The Director will maintain appropriate awareness of modern slavery risks and current guidance, and relevant information will be shared with associates or partners where the nature of their work or purchasing responsibilities makes this appropriate.

10. Monitoring and Review

Our approach will be kept under review and updated where the nature of our work, suppliers, supply chains or identified risks change. Material concerns and actions taken will be recorded appropriately, subject to confidentiality and data protection requirements.

This policy will be reviewed annually and updated as necessary to remain effective, proportionate and consistent with relevant legislation and public-sector procurement guidance.

Policy last reviewed: 24.08.2026
Next review date: 24.08.2027