Human Trafficking and Modern Slavery Policy

Human Trafficking and Modern Slavery Policy

1. Purpose

CSM Property Management Ltd is committed to conducting business ethically, transparently, and in full compliance with applicable laws and regulations, including the Modern Slavery Act 2015.

We are firmly opposed to all forms of slavery, servitude, forced labour, and human trafficking. This policy outlines our commitment to preventing such practices within our business operations and supply chains.

2. Scope

This policy applies to:

• All employees, contractors, and agency staff engaged by CSM Property Management Ltd;

• All suppliers, subcontractors, and service providers who work with or on behalf of CSM; and

• Any other third parties who have a business relationship with the company.

Every person working for or with CSM is expected to uphold the highest standards of integrity and take a zero-tolerance approach to modern slavery in all its forms.

3. Policy Statement

CSM Property Management Ltd recognises that modern slavery is a crime and a violation of fundamental human rights. We are committed to:

• Acting ethically and with integrity in all our business dealings;

• Implementing and enforcing effective systems and controls to ensure modern slavery is not taking place in any part of our business or supply chain;

• Ensuring transparency in our operations, consistent with our disclosure obligations under the Modern Slavery Act; and

• Encouraging our employees and suppliers to report any concerns regarding potential breaches of this policy.

4. Our Business and Supply Chains

CSM Property Management Ltd provides block and estate management services across Northern Ireland.Our supply chains include contractors and service providers such as cleaning companies, maintenance firms, electricians, plumbers, insurers, and professional advisers.

We work only with suppliers and partners who share our values and comply with all applicable labour, welfare, and human rights legislation. Where possible, we engage with local and reputable suppliers with demonstrable compliance procedures.

5. Risk Assessment and Due Diligence

We recognise that the property and facilities management sectors can present risks of labour exploitation, particularly through subcontracted or casual workforces.
To mitigate these risks, we:

• Conduct due diligence on all new suppliers and contractors;

• Require confirmation that suppliers comply with the Modern Slavery Act 2015;

• Maintain the right to audit suppliers or terminate contracts if evidence of non-compliance arises;

• Ensure staff involved in procurement or contractor management are aware of modern slavery risks and warning signs.

6. Reporting Concerns

Any employee, contractor, or third party who suspects that modern slavery or human trafficking is occurring in connection with CSM’s operations should report their concerns immediately.

Reports can be made confidentially to a senior manager or directly to:

📧 info@csmni.com
📞 028 90245999

All concerns will be investigated promptly, fairly, and sensitively. Whistleblowers will not face retaliation or adverse treatment for raising a concern in good faith.

7. Training and Awareness

CSM will provide relevant staff with training to raise awareness of modern slavery and human trafficking risks. This includes understanding potential indicators, how to escalate concerns, and how to apply due diligence when engaging contractors or suppliers.

8. Responsibility for Implementation

Overall responsibility for this policy rests with the Board of Directors of CSM Property Management Ltd. Managers are responsible for ensuring staff understand and comply with the policy, and for reporting any potential breaches to senior management.

All employees have a duty to act ethically, report concerns, and help maintain a culture of integrity across the company.

9. Review and Monitoring

This policy will be reviewed annually or sooner if required by changes in legislation, business operations, or identified risks. Updates will be communicated to staff and suppliers where relevant.

CSM Property Management Ltd
www.csmni.com
Committed to ethical business, fair employment, and zero tolerance for modern slavery.