This statement applies to Thomas Graham & Sons Ltd (referred to in this statement as “the Organisation”). This statement is made in pursuance of Section 54 (1) of the Modern Slavery Act 2015 for the financial year to 31st May 2022. The statement has been approved by the Board of Directors and will be reviewed annually. A signed copy is held at the Company’s registered office.

Organisation Structure

The Organisation is an independent industrial supplies and steel stockholder, with trading operations in the United Kingdom controlled by a Board of Directors.

Our Registered Office is Spellar Way, Kingmoor Park East, Carlisle, Cumbria, CA6 4SQ, with 3 additional depots across Cumbria and North Lancashire, employing 200 staff across the organisation.


The Organisation considers that modern slavery encompasses:

  • Human Trafficking
  • Forced or Compulsory Labour, through mental or physical threat or coercion.
  • Servitude – being owned or controlled by an Employer through mental or physical abuse or the threat of abuse.
  • Dehumanisation – being treated as a commodity or being bought or sold as property.
  • Physical Constraint – having a restriction placed on freedom of movement.

Supply Chain & Safeguards

The Organisation have implemented a process under which we require our top 100 suppliers to provide us with details of the steps that they have taken to ensure that slavery and human trafficking are not taking place in their business or their respective supply chains. We will require that compliance with our policy is a condition of becoming and remaining one of our Accredited Suppliers.

The Organisation does not knowingly deal with any businesses involved in slavery or human trafficking, but it does understand that this is a hidden problem that must be tackled in conjunction with recruitment, personnel/ agencies, suppliers, and contractors.

Potential Exposure

In general, the Organisation considers its exposure to slavery and human trafficking to be relatively limited. It has taken steps to ensure that such practices do not take place in its business practices nor the business of any organisation that supplies goods and/or services to it.


The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place within our organisation or our supply chain. We have not, to our knowledge conducted any business with another organisation who have been found to have involved itself with modern slavery.

During this financial year, we are taking the following steps to ensure that modern slavery is not taking place:

  • Recruitment guidelines are in place to ensure entitlement to work and to prevent forced or bonded labour.
  • Commitment to pay our own minimum wage which is set at a higher rate than the national minimum or living wages issued by HMRC.
  • Including in our Supplier Questionnaires specific questions regarding Modern Slavery.
  • Review of our supply chain to identify any potential risks.
  • Training all our employees to be able to identify the possible signs of modern slavery.

Key Performance Indicators

The Organisation has set the following KPI’s to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

  • Returned Supply Chain Questionnaires to be reviewed for Modern Slavery commitment and processes for suppliers.
  • Training planned for management and staff about grievance and whistle-blowing procedures for employees and workers if cases are suspected or found.
  • Raise awareness among all employees to ensure understanding of the risks of modern slavery and human trafficking in our business. The policy is included in the Policy handbook.
  • A full review of relevant policies and procedures is being undertaken during this financial year, as part of an overall review of people policies across the organisation.

This Statement will be reviewed on an annual basis and posted on our company website.

You can access our Modern Slavery & Human Trafficking Policy by clicking here.



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