1. Introduction

Modern slavery is a serious crime and a grave violation of fundamental human rights. It takes many forms — including slavery, servitude, forced and compulsory labour, and human trafficking. All these forms involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Pearl Security has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Although Pearl Security is currently below the annual turnover threshold at which the Modern Slavery Act 2015 requires mandatory annual transparency statements, we have chosen to adopt this policy voluntarily — because we believe it is the right thing to do, because the security industry has historically been identified as a sector at elevated risk of labour exploitation, and because our clients — including logistics, construction and retail operators — increasingly require this commitment from all suppliers.

2. Legal Framework

This policy is established in compliance with and with reference to:

• Modern Slavery Act 2015 — the primary UK legislation criminalising slavery, servitude, forced labour and human trafficking
• National Minimum Wage Act 1998 — ensuring all workers receive lawful pay
• Employment Rights Act 1996 — workers’ rights and protection from exploitation
• Gangmasters (Licensing) Act 2004 — relevant to labour supply in the security industry
• Immigration, Asylum and Nationality Act 2006 — right to work verification obligations
• Home Office UK Modern Slavery Guidance 2023

3. Our Commitments

Pearl Security commits to the following in relation to modern slavery and human trafficking:

• We will never knowingly engage, employ or contract with any individual or organisation involved in modern slavery or human trafficking
• We will verify the right to work in the UK for every employee and security officer before employment commences
• We will pay all employees and security officers at least the National Living Wage — and never make unlawful deductions from wages
• We will never hold or confiscate the identity documents or passports of any employee or officer
• We will never charge recruitment fees to any employee or officer
• We will ensure all employment contracts are clear, transparent and written in a language the individual can understand
• We will conduct due diligence on all suppliers and contractors to identify and address modern slavery risks
• We will provide a safe, confidential reporting mechanism for any employee, officer or third party who suspects modern slavery

4. Risk Assessment — The Security Industry Context

The UK security industry has been identified by the Home Office and the Gangmasters and Labour Abuse Authority (GLAA) as a sector at elevated risk of labour exploitation. Specific risk factors include:

• Use of agency workers and sub-contractors — creating potential for exploitation further down the supply chain
• Overnight and weekend working patterns that may be used to exploit vulnerable workers
• Employment of workers from overseas who may be vulnerable to exploitation
• Underpayment of wages or unlawful deductions masked by complex shift arrangements

Pearl Security directly addresses these risks through its direct employment model, BS 7858:2019 vetting of all staff, right-to-work verification, transparent pay arrangements and direct management of all operatives.

5. Due Diligence

Pearl Security conducts due diligence in relation to modern slavery risks as follows:

5.1 Employment Due Diligence

• Right to work in the UK is verified for every employee and officer before commencement of employment
• Identity is verified as part of BS 7858:2019 vetting — including photographic ID and address verification
• Employment contracts are provided to every employee and officer in writing before their first shift
• Pay is processed transparently with itemised payslips provided to all staff
• No recruitment fees are charged to any employee or officer at any stage

5.2 Supply Chain Due Diligence

• We assess all suppliers and contractors for modern slavery risk before engagement
• We require all suppliers and contractors to confirm their compliance with the Modern Slavery Act 2015
• We will not engage sub-contractors to deliver security services without first verifying their SIA licensing, employment practices and modern slavery compliance

6. Reporting Concerns

Pearl Security encourages all employees, officers, clients and third parties to report any concern about modern slavery — whether within our own operations or in our supply chain. Reports can be made:

• Internally — directly to the Director, Muhammad Khan, at contact@pearlsecurity.co.uk or +44 (0) 7481 153593
• Externally — to the Modern Slavery Helpline: 0800 0121 700 (free, 24/7, confidential)
• To the police — call 101 or 999 in an emergency
• To the Gangmasters and Labour Abuse Authority (GLAA) — gla.gov.uk

Pearl Security will not tolerate any retaliation against any person who raises a genuine concern about modern slavery in good faith.

7. Training and Awareness

Pearl Security ensures that all employees and officers are aware of:

• What modern slavery is and how to recognise it
• The signs of forced labour, trafficking and exploitation
• How to report a concern — internally and externally
• Their own rights as workers under UK employment law

This awareness is built into the onboarding process for all new employees and officers and is reinforced periodically.

8. Policy Review

This Modern Slavery Policy will be reviewed by the Director at least annually and updated to reflect changes in legislation, guidance or our operational practices. We are committed to continuous improvement in our approach to identifying and addressing modern slavery risks.

9. Contact