This statement is made by the Directors of Carlton Huxley Ltd ("Carlton Huxley", "we" or "our") pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Carlton Huxley's modern slavery and human trafficking statement. 

1. Introduction 

Carlton Huxley is committed to conducting its business in a responsible and ethical manner. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain. In this regard, the same high standards we apply to our business are expected of our suppliers and those we do business with. 

2. Carlton Huxley Ltd 

Carlton Huxley is a professional services firm providing Legal and Law enforcement advisory services. Carlton Huxley 's main operations are in the UK and we employ around 20 people. 

To find out more about the nature of our business, please click www.carltonhuxley.com. 

Carlton Huxley considers the professional services industry to be relatively low risk on the scale of risk for modern slavery, and the primary focus for the purposes of assessing risk of modern slavery and human trafficking in respect of our business rests in our supply chain. 

3. Policies 

Carlton Huxley has a zero-tolerance approach to any form of slavery and human trafficking. A risk-based approach is used to assess the likelihood of modern slavery occurring and we operate a range of policies and processes to identify and mitigate modern slavery risks. 

We also make sure our suppliers are aware of our policies and adhere to the similarly high standards. 

Our policies and processes reflect our commitment to act ethically and with integrity in all our business relationships and to identify and eradicate modern slavery practices from our business and our supply chain, to the extent that they exist. 

4. Due diligence 

As part of our efforts to identify and mitigate risk we have put in place systems to: 

•    identify and assess areas of potential risk in our business and supply chains; 

•    monitor potential risk areas in our business and supply chains; 

•    reduce the risk of slavery and human trafficking occurring in our business and supply chains; and 

•    provide protection for whistleblowers. 

 

5. Supply chain risk 

In the provision of our services, we work with a range of suppliers, although, as a professional services firm, our supply chains are limited. 

Our supply chain includes external suppliers (such as IT support, office goods suppliers and office support service suppliers) as well as professional service advisers. Most suppliers are expected to be based in the UK. 

We take a risk-based approach to understanding and monitoring our supply chain and expect all suppliers to take a zero-tolerance approach to modern slavery and human trafficking. 

Any new supplier is subject to a due-diligence on-boarding process which includes consideration of the quality of their services, ethics and ways of working. Most suppliers will come from recommendations from trusted third parties. Carlton Huxley will regularly evaluate the nature and extent of our exposure to the risk of modern slavery occurring in our supply chain. 

We do not tolerate slavery and human trafficking within our supply chains. If we did find evidence of a failure to comply with responsible and ethical working practices we will immediately seek to terminate our relationship with the relevant supplier. 

6. Effectiveness 

As noted, we will screen suppliers and carry out periodic reviews (as well as considering any reported breaches and gaps in our training programme) in order to assess whether our procedures are helping to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains. 

7. Training 

We invest in educating our team to recognise the risks of modern slavery and human trafficking in our business and supply chains. Employees are encouraged to identify and report any potential breaches. The benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains are made clear to all staff through training. 

8. Further actions and sign-off 

As a new business, Carlton Huxley is taking steps to ensure that our business and supply chain is not involved in any form of modern slavery or human trafficking from the outset. The actions we take over the course of this financial year will be designed to ensure we continue to enhance our procedures to identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new or existing suppliers. Any potential improvements to our procedures and training which are identified will be acted upon as necessary. 

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Carlton Huxley’s slavery and human trafficking statement. 

 

This statement was approved by the Directors of Carlton Huxley Ltd on 20th April 2022 and will be reviewed at least annually.