Modern Slavery & Human Rights Policy

Reviewed: 29 January 2026

At a glance

  • Zero tolerance of modern slavery, human trafficking, forced, bonded or child labour, and exploitation in any form.
  • We follow the Modern Slavery Act 2015, Human Rights Act 1998, the UN Guiding Principles on Business & Human Rights (UNGPs) and relevant ILO Core Conventions.
  • We operate a risk‑based due‑diligence programme for recruitment and suppliers, with clear remediation, escalation, and reporting channels (including anonymous reporting where permitted by law).

Purpose

To set out UK Postbox’s commitments and procedures to prevent, detect and remediate modern slavery and human rights abuses within our business and supply chain, and to comply with applicable UK law and international standards.

Scope

  • Our workforce: all employees (permanent, fixed‑term, part‑time), agency workers, interns and contractors engaged by UK Postbox.
  • Our supply chain: all third parties providing goods or services, including technology vendors, KYC/biometric providers, carriers, facilities and equipment suppliers, and any sub‑contractors/sub‑processors they use to deliver services to UK Postbox.

Our commitments

  • Respect human rights: uphold the dignity, welfare and equal rights of all workers.
  • Prohibit forced labour: no forced, bonded, indentured, prison, or compulsory labour; no human trafficking.
  • Prohibit child labour: no employment of anyone below the minimum age for work as defined by law and ILO standards; additional protections for young workers.
  • No fees (Employer Pays Principle): workers shall not pay recruitment fees or related costs to obtain or retain employment. Any fees paid must be reimbursed.
  • Fair treatment: zero tolerance of harassment, abuse or inhumane treatment; no discrimination based on protected characteristics (see Equality Act 2010).
  • Freedom of movement and association: Original identity documents will not be retained except where legally required and for the minimum period permitted by law.
  • Wages and working hours: meet or exceed legal requirements; provide clear written terms and payslips.
  • Safe, healthy workplace: maintain safe working conditions; provide necessary PPE and training.
  • Remedy: provide or cooperate in effective remediation where we identify harm.

Governance & responsibilities

  • Board/Executive Sponsor: approves this Policy and the annual Modern Slavery Statement; oversees risk appetite and resources.
  • Compliance Lead (Policy Owner): maintains this Policy and the due‑diligence framework; coordinates the annual statement, training, and KPI reporting.
  • Procurement Lead: embeds requirements in supplier onboarding, contracts and performance management.
  • People/HR Lead: ensures ethical recruitment, right‑to‑work checks, fair contracts and worker support.
  • Managers: ensure team compliance and promptly escalate concerns.
  • All staff and suppliers: must comply with this Policy and report any suspicion or breach immediately.

Due diligence — recruitment & employment

  • Right‑to‑work: verify identity and legal right to work; no retention of original identity documents beyond what the law permits.
  • No recruitment fees: we require written confirmation from all recruitment agencies that they do not charge workers any fees, and we include contractual audit rights to verify compliance.
  • Contracts & payslips: provide written terms in a language workers understand; transparent pay and deductions; meet or exceed minimum wage and working‑time rules.
  • Grievance access: all workers have access to confidential grievance channels and are protected from retaliation. We encourage worker feedback through regular engagement surveys, team meetings, and confidential reporting channels to identify any concerns early.
  • Training: managers and HR receive training on indicators of modern slavery and how to escalate concerns.

Due diligence — suppliers & partners

  • Pre‑contract screening: risk‑based questionnaires covering labour standards, recruitment practices (including use of agencies), working hours, wages, grievance mechanisms, and sub-contractor management.
  • Contractual requirements: suppliers must comply with this Policy and our Supplier & Partner Code of Conduct; flow‑down to their sub‑contractors; allow audits and provide evidence upon request.
  • Ongoing assurance: higher‑risk suppliers (including those in sectors with known modern slavery prevalence such as logistics, cleaning, security, and manufacturing; those operating in high-risk geographies; or those with complex subcontracting arrangements) may be required to provide certificates, independent assessments or improvement plans; we may perform site visits or remote audits.
  • Change notification: suppliers must notify us of material changes, incidents or enforcement actions related to labour practices.

Red flags & indicators

We train staff to identify indicators such as: restriction of movement; retention of passports; recruitment fees or debt bondage; excessive overtime; underpayment; intimidation; lack of written terms; or workers unable to speak for themselves.

Reporting concerns (whistleblowing)

  • How to report: employees and third parties can report concerns to ethics@ukpostbox.com or via our confidential Speak Up channel (anonymity where permitted by law).
  • Non‑retaliation: we prohibit retaliation against anyone who raises a concern in good faith.
  • External reporting: where criminality is suspected, we may contact law enforcement or relevant authorities.

Response, remediation & escalation

  • Triage & investigation: Compliance will assess and, where necessary, investigate with HR/Procurement and, if applicable, the supplier.
  • Immediate safety: take steps to protect affected individuals and prevent further harm. Where workers have been harmed, we will prioritise their welfare and cooperate with specialist organisations to provide appropriate support, which may include access to legal advice or counselling.
  • Corrective action plans: agree time‑bound remediation with suppliers (e.g., repayment of fees to workers, policy changes, training, improved working conditions).
  • Termination: where remediation fails or risk is severe/unremediable, we may suspend or terminate the relationship.
  • Documentation: keep records of findings, actions and outcomes for audit and our annual statement.

Training & awareness

  • Induction training within 14 days of start and annual refreshers for all staff in procurement, HR, operations and supplier‑facing roles.
  • Targeted refreshers for high‑risk categories (e.g., carriers/logistics, facilities).
  • Guidance materials on identifying red flags and using reporting channels.

Data protection & confidentiality

We process any personal data collected during due diligence, reporting or investigations in line with UK GDPR, our Data Protection Policy, and the Privacy Notice. We protect confidentiality and only share data on a need‑to‑know basis or where required by law.

Annual Modern Slavery Statement

Where required under Section 54 of the Modern Slavery Act 2015 (organisations with annual turnover of £36 million or more), we publish an annual statement on our website describing our structure, supply chains, policies, risk assessment, due diligence, training, KPIs and effectiveness measures for the financial year. The statement is approved by the Board and signed by a director. Although UK Postbox may not be legally required to publish a statement under Section 54, we choose to do so voluntarily in line with best practice.

UK Postbox Limited

13 Freeland Park, Wareham Road, Lytchett Matravers, Poole, Dorset, BH16 6FH, United Kingdom


Support: support@ukpostbox.com

Security: security@ukpostbox.com

Legal notices: legal@ukpostbox.com

Data protection: dpo@ukpostbox.com

Complaints: complaints@ukpostbox.com

Accessibility: accessibility@ukpostbox.com

Website: www.ukpostbox.com


Registered in England and Wales Company Number: 06723381

MLR registration no: XLML00000192390

ICO registration no: ZA038907