This policy is endorsed and approved by the directors.
Signed by Alex Warren, CEO
1. Purpose, Scope & Users
What is slavery?
1.1 The Modern Slavery Act (MSA) 2015 covers four activities:
- Slavery – Exercising powers of ownership over a person
- Servitude – The obligation to provide services is imposed by the use of coercion
- Forced or compulsory labour – Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
- Human trafficking – Arranging or facilitating the travel of another person with a view to their exploitation
1.2 This policy covers all four activities.
2. How is it relevant to us?
2.1 Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. At first glance, you may think this whole subject is irrelevant to us, but it’s not.
2.2 At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.
2.3 The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
2.4 With this in mind, we need to pay particularly close attention to:
2.4.1 our supply chain
2.4.2 any outsourced activities, particularly to jurisdictions that may not have adequate safeguards
2.4.3 cleaning and catering suppliers
3. Responsibilities
3.1 Stark, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
3.2 Everyone must observe this policy and be aware that turning a blind eye is unacceptable and simply not an option.
3.3 Stark’s responsibilities
3.3.1 We will:
(a) maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation;
(b) be clear about our recruitment policy (see Recruitment);
(c) check our supply chains (see Supply chains);
(d) lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us;
(e) ensure we have in place an open and transparent grievance process for all staff;
(f) seek to raise awareness so that our colleagues know what we are doing to promote their welfare; and
(g) make a clear statement to demonstrate that we take our responsibilities to our employees and our clients seriously (see Anti-slavery statement)
3.4 Manager responsibilities
3.4.1 Managers will:
(a) listen and be approachable to colleagues;
(b) respond appropriately if they are told something that might indicate a colleague or any other person is in an exploitative situation;
(c) remain alert to indicators of slavery (see Identifying slavery);
(d) raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do; and
(e) use their experience and professional judgement to gauge situations.
3.5 Colleagues
3.5.1 We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
(a) keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery);
(b) follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated; and
(c) tell us if you think there is more we can do to prevent people from being exploited.
4. The risks
4.1 The principal areas of risk we face, related to slavery and human trafficking, include:
4.1.1 supply chains;
4.1.2 recruitment through agencies; and
4.1.3 general recruitment.
4.2 We manage these risk areas through our procedures set out in this policy and elsewhere.
5. Our procedures
5.1 Anti-slavery statement
5.1.1 We make a clear statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees, people working within our supply chain and our clients seriously.
5.1.2 We make this statement through this policy and others. This policy sets out the key risk areas we face and our approach to avoiding and preventing modern slavery.
5.1.3 Our statement
Stark is a data champion. We serve over 30,000 non-domestic customers across all sectors of the UK economy. We deliver significant value to energy suppliers, industrial and commercial companies, public sector organisations, and energy and procurement consultants.
Stark is committed to helping to combat modern slavery, servitude, human trafficking, forced labour, and child labour. Stark has a zero-tolerance approach to any form of child labour, modern slavery, and people trafficking. We operate a number of policies to ensure that we are conducting business in an ethical and transparent manner, including:
1. Anti-slavery and child labour policy which sets out our stance on modern slavery, forced labour, and child labour and explains how employees should report any concerns.
2. Recruitment & Selection policy which includes conducting eligibility to work in the UK checks for all employees in an effort to ensure individuals are not being forced to work against their will, and use of only specified and reputable employment agencies/sources of labour to source employees.
3. Whistleblowing policy ensuring that employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4. Employee Code of Conduct which makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
5. Anti- Corruption Policy which sets out our commitment to applying the highest standards of ethical conduct and integrity in all our business activities.
5.2 Supply chains
5.2.1 We thoroughly check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
5.2.2 We tell the companies we do business with that we are not prepared to accept any form of exploitation.
5.2.3 All our supplier contracts contain an anti-slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking.
5.2.4 We ensure we can account for each step of our supply processes—we know who is providing goods and services to us and we have mechanisms and processes in place to check, including:
(a) supplier mapping;
(b) risk assessing suppliers; and
(c) auditing suppliers.
5.3 Recruitment
5.3.1 Using agencies
(a) Our HR department only uses agreed specified reputable recruitment agencies.
(b) To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:
(i) conducting background checks;
(ii) investigating reputation;
(iii) ensuring the staff an agency provides have the appropriate paperwork (eg work visas);
(iv) ensuring the agency provides assurances that the appropriate checks have been made on the person they are supplying; and
(c) We keep agents on the list under regular review, at least every 3 years.
5.3.2 General recruitment
(a) We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work;
(b) We always ensure staff are legally able to work in the UK;
(c) We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited); and
(d) We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
5.4 If, through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures.
6. Identifying slavery
6.1 There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
6.2 However, the following key signs could indicate that someone may be a slavery or trafficking victim:
6.2.1 the person is not in possession of their own passport, identification or travel documents;
6.2.2 the person is acting as though they are being instructed or coached by someone else;
6.2.3 they allow others to speak for them when spoken to directly;
6.2.4 they are dropped off at and collected from work;
6.2.5 the person is withdrawn or they appear frightened;
6.2.6 the person does not seem to be able to contact friends or family freely; and
6.2.7 the person has limited social interaction or contact with people outside their immediate environment.
6.3 This list is not exhaustive.
6.4 Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
6.5 If you have a suspicion, report it.
7. Reporting slavery
7.1 Talking to someone about your concerns may stop someone else from being exploited or abused.
7.2 If you think that someone is in immediate danger, dial 999.
7.3 Any employee who suspects a Modern Slavery situation either home or at work is encouraged to report it to the Police or via the Modern Slavery Helpline.
7.4 Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with a member of the HR Department before taking any further action.
8. Training
8.1 We provide specialist training to those staff members who are involved in managing recruitment and our supply chains.
8.2 Mandatory and refresher training for all Stark employees on employment includes Equality Diversity & Inclusion and Unconscious Bias awareness training.
8.3 Online Modern Slavery Training is issued to all employees involved with Supply Chain management.
8.4 Awareness of Modern Slavery will have a Stark internal SharePoint page from Autumn 2023.
9. Monitoring our procedures
9.1 We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.
Last reviewed
16 July 2026
