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Modern Slavery and Human Trafficking Statement

Last updated: March 2026

Introduction and commitment

This statement is published voluntarily by Pioneer Wall Cladding & Building Insulation Ltd and mirrors the structure of Section 54 of the Modern Slavery Act 2015, notwithstanding that we are below the £36 million turnover threshold at which publication becomes a statutory requirement. Given our extensive work with public-sector funders, retrofit programmes and vulnerable households, we consider transparency about how we manage the risk of modern slavery and human trafficking to be a basic condition of doing this work well.

We do not tolerate any form of slavery, servitude, forced or compulsory labour, human trafficking, child labour, unlawful discrimination or worker exploitation — whether within our own workforce, on our sites, or anywhere in our supply chain. Every supplier, subcontractor and specialist we engage is required to demonstrate the same standard as a condition of working with us.

We are a small, direct-labour business. Every insulation operative on our sites is engaged under an individual contract, paid by BACS into their own named bank account, and known personally to our management team. We do not engage labour-only intermediaries, ad-hoc labour groups, or third-party wage distributors. This direct-employment model is the foundation of our modern slavery risk mitigation — it removes at source the sector’s principal risk vector: transient labour supplied through unmonitored intermediaries.

Organisation, business and supply chains

Pioneer Wall Cladding & Building Insulation Ltd is an independent, family-run UK limited company registered in England 07974658. We have no parent, subsidiary or overseas entities, and our workforce is based entirely in the UK.

We specialise in External Wall Insulation, Internal Wall Insulation, Cavity Wall Insulation, Loft Insulation, Underfloor Insulation and Park Home insulation, delivering PAS 2030 / PAS 2035 compliant retrofit works for private homeowners and Local Authority-funded fuel-poor schemes (HUG, ECO4, WHLG and successor programmes) across Surrey, London and the wider South East.

Our supply chain has three principal components:

  • Direct employees — installers, supervisors, retrofit designers and office staff, all directly engaged on individual UK contracts.
  • Materials and system suppliers — a small number of long-standing UK-based system suppliers. We hold direct commercial relationships with each Tier-1 supplier.
  • Specialist sub-contractors — used selectively for measures outside our direct PAS 2030 scope (e.g. scaffolding, gas engineering, specialist plumbing and drainage), always under written contract and subject to our approval process.

Our small size and streamlined supply chain give us direct visibility of every tier, and we know our operatives personally. We have mapped the full supply chain for key materials, products and services and understand where our core inputs originate and who the key suppliers are at each relevant tier.

Policies in relation to slavery and human trafficking

Our Modern Slavery and Human Trafficking Policy is signed by the Managing Director and refreshed each year. It is supported by a wider set of internal policies and procedures that between them cover recruitment integrity, worker welfare, procurement discipline and confidential reporting:

  • Recruitment, Vetting and Right-to-Work Procedure
  • Confidential Reporting (Whistleblowing) Policy — anonymous, third-party operated, available in multiple languages
  • Anti-Bribery and Corruption Policy
  • Supplier and Subcontractor Onboarding and Assessment Procedure
  • Health and Safety Policy, supported by site-specific Method Statements and Risk Assessments
  • Equality, Diversity and Inclusion Policy
  • Fair Pay Policy (National Living Wage baseline)
  • Data Protection and GDPR Policy
  • Modern Slavery Escalation and Reporting Procedure — the internal route for raising, investigating and escalating any suspected incident

Taken together, these documents translate our zero-tolerance position into day-to-day operating practice, ensuring that respect for fundamental human and labour rights and lawful employment sit at the core of how we hire, buy and deliver.

Due diligence processes

Our due diligence covers both our workforce and our supply chain.

Workforce.

Every direct employee and contracted operative undergoes a right-to-work check on engagement, with document expiries diarised and re-checked before lapse. All operatives are engaged on individual contracts; we do not use ad-hoc labour groups, unnamed labour supply, or third-party wage intermediaries. All wages are paid directly by BACS into the named individual’s own bank account. As a family-run business, we recruit operatives directly, build working relationships with each individual, and maintain clear oversight of working arrangements, enabling us to identify potential concerns or warning signs at an early stage.

Supply chain.

New suppliers undergo similar checks and contracts are in place to ensure their compliance with the Modern Slavery Act 2015, right-to-work verification of all operatives, adherence to National Minimum Wage and Working Time Regulations, and HMRC Construction Industry Scheme (CIS) registration for any labour-supplying sub-contractor. Existing suppliers are re-checked at least every 24 months, or immediately on any change of control.

We will not engage any supplier appearing on the UK Sanctions List, the Department for Business and Trade’s National Minimum Wage naming list, the Home Office’s list of employers subject to illegal-working civil penalties, or any supplier subject to a current Fair Work Agency labour-market enforcement undertaking or order.

Risk assessment and areas of higher risk

Within our own operations we have assessed the following as the principal risk areas within our sector, and the mitigations we apply to each:

Transient and agency labour in the retrofit sector.

A significant proportion of insulation labour in our industry is transient, and some workers are non-UK nationals with limited or no command of English. This is the retrofit sector’s highest-risk area. Our mitigation is direct employment: we engage each operative individually, do not use intermediaries, do not permit ad-hoc labour groups on site, and build direct working relationships with every operative. Our supervisors are trained to recognise early warning signs including isolation from other workers, being picked up or dropped off by third parties, poor language skills combined with no fixed address, retained ID or bank cards, and signs of physical or emotional distress or abuse.

Materials sourced from higher-risk countries.

Managed through our supplier Pre-Qualification Questionnaire, ongoing supplier review process and preference for long-standing UK-based system suppliers.

Specialist sub-contractors used at Call-Off level.

Managed through our subcontractor approval process, with mandatory flow-down of modern slavery obligations, right-to-work verification and prompt-payment requirements in every sub-contract.

Our compliance with immigration law, minimum-wage regulations, working-time limits, rest breaks and correct remuneration is monitored continuously through payroll, HR and site-supervision records.

Effectiveness — key performance indicators

We track the following indicators annually and will report against them to public-sector clients on request:

  • Percentage of direct employees and contracted operatives with valid, in-date right-to-work verification (target: 100%).
  • Percentage of active suppliers with completed and in-date Supplier PQQ (target: 100%).
  • Number of concerns raised via the whistleblowing route, with time-to-resolution.
  • Percentage of all staff completing annual Modern Slavery awareness training (target: 100%).

Since Pioneer Wall Cladding & Building Insulation Ltd was established, no incidents of modern slavery or human trafficking have ever been identified within our operations or supply chain, and no substantiated concerns have been raised through our whistleblowing route, our supervisor channels, or by any external body. This position is confirmed as at the end of the financial year ended 28 February 2026 and to the date of this statement.

Training and capacity building

All our employees receive Modern Slavery awareness training at induction, with a refresher module completed annually. Our site supervisors, project managers and procurement staff complete training covering the practical indicators of exploitation (poor accommodation, controlled communication, retained ID, signs of injury or malnutrition), the escalation route within our business, and the mandatory external reporting route to the Fair Work Agency and the Modern Slavery Helpline.

Approval and review

This statement has been reviewed and approved by our senior management. It will be reviewed annually, or sooner if legislation, our business circumstances, workforce composition or supply chain composition change materially. The current version is published on our website.