Legal
Modern slavery policy
Construction carries a real risk of forced labour and debt bondage, most of it several tiers down a subcontract chain. This sets out what we do about it — who we check, what we ask for, and what happens when something looks wrong.
- Version
- 2.0
- Last updated
- 4 August 2026
- Financial year
- Year ended 31 March 2026
- Applies to
- FF Construction Ltd and our whole supply chain
- Status
- Draft — pending board approval
Words we use
- Modern slavery
- Slavery, servitude, forced or compulsory labour and human trafficking
- Debt bondage
- Work extracted to repay a debt the worker cannot realistically clear
- Our supply chain
- Every subcontractor, labour agency, supplier and haulier working on our projects
- The Act
- The Modern Slavery Act 2015
Our commitment
We do not tolerate modern slavery in our business or in our supply chain, and we expect the same of everyone we contract with. Nobody working on one of our sites should have paid a fee to get there, be holding someone else’s documents, or be unable to leave.
This policy applies to every director, employee, agency worker and subcontractor. It is reviewed each year by the board.
Our business and supply chain
We are a commercial construction and property services contractor based in Oxford, working across Oxfordshire and the Thames Valley. We employ our site management and core trades directly, which removes a whole layer of agency labour from the highest-risk part of the chain.
The risk that remains sits with specialist subcontractors, labour agencies used at peak, and materials bought through distributors — particularly where a product is manufactured outside the UK and we cannot see past the importer.
What we require of subcontractors
Every subcontractor confirms in writing that it complies with the Act and that it flows the same requirement down to anyone it engages.
Labour agencies confirm they hold the licences their sector requires, and that no worker has been charged a fee to obtain work.
We check right-to-work documents against the person presenting them at induction, not in advance and not by photograph.
We pay subcontractors on the terms we agreed. Late payment down a chain is one of the conditions in which exploitation takes hold, so this is a control and not a courtesy.
A subcontractor that will not accept these terms does not go on our list, whatever the price.
What we look for on site
Site managers are briefed on the indicators: several workers sharing one bank account or one address, someone else holding a worker’s documents, a worker who cannot say who employs them or what they are paid, transport controlled by a third party, and reluctance to speak without a particular colleague present.
None of these proves anything on its own. All of them are reasons to ask more questions, and no site manager is expected to resolve it alone.
Raising a concern
Anyone — employee, subcontractor, agency worker or member of the public — can raise a concern with a site manager or directly with a director at directors@ffconstruction.co.uk. Concerns can be raised anonymously.
We do not penalise anyone for raising a concern in good faith, including where it turns out to be mistaken. Retaliating against someone who has raised one is itself a disciplinary matter.
Where there is an immediate risk to someone, call 999. The Modern Slavery Helpline is 08000 121 700.
What we did this year
The figures below cover the year ended 31 March 2026 and are the measures the board reviews.
- Subcontractors on the approved list
- 148, all with signed compliance confirmations
- Site inductions delivered
- 612, each covering how to raise a concern
- Supply chain audits
- 9, focused on agency labour and imported materials
- Concerns raised
- 2, both investigated and closed
- Confirmed cases
- None
Approval
This policy is approved by the board of FF Construction Ltd and signed by a director on its behalf. We review and republish it annually.
Report a concern
If something you have seen on one of our sites does not look right, tell us. You can do it anonymously, you do not need to be sure, and nobody is penalised for raising it.
Email hello@ffconstruction.co.uk or call 01865 000 000. By post: FF Construction Ltd, Unit 4, Osney Mead , Oxford, OX2 0ES.