Last reviewed: 5 August 2026

Stormspell Limited is committed to conducting business ethically, responsibly and with respect for human rights. We have zero tolerance for slavery, servitude, forced or compulsory labour, human trafficking, child labour and other forms of exploitation in our business or supply chains.

This policy applies to everyone working for or on behalf of Stormspell Limited, including directors, employees, agency workers, contractors, consultants, suppliers, manufacturers, hauliers and other business partners.

1. Purpose and legal context

The Modern Slavery Act 2015 makes slavery, servitude, forced or compulsory labour and human trafficking criminal offences. Section 54 of the Act also requires certain commercial organisations carrying on business in the United Kingdom and having total annual turnover of £36 million or more to publish a slavery and human trafficking statement for each financial year.

This page sets out Stormspell’s continuing policy and approach. It is not presented as a statutory annual section 54 statement for a particular financial year. We will assess whether the section 54 reporting requirements apply and, where they do, publish a separate annual statement describing the steps taken during the relevant financial year. A statutory statement must be approved by the board, signed by a director and published in accordance with the Act and current government guidance.

2. Our business and supply chains

Stormspell Limited supplies roofing and building materials to trade and other customers through its branches, website and delivery services. Our supply chains may include:

• UK and overseas manufacturers of roofing, timber, insulation, plastics, metals, windows, membranes, fixings, tools and related products;
• wholesalers, distributors and importers;
• transport, haulage, courier and delivery providers;
• temporary labour, recruitment and professional-service providers; and
• technology, facilities, cleaning, maintenance and other operational suppliers.

We recognise that modern-slavery risk can occur at any stage of a supply chain, particularly where there are complex international supply chains, labour-intensive manufacturing, subcontracting, temporary or migrant labour, recruitment intermediaries, low-paid work or limited visibility beyond a direct supplier.

3. Our standards

We expect our own operations and business partners to support the following principles:

• employment must be freely chosen and workers must be free to leave in accordance with lawful notice requirements;
• no worker may be subjected to forced, bonded, indentured or prison labour, slavery, servitude or human trafficking;
• workers must not be charged recruitment fees or required to lodge deposits as a condition of work;
• workers’ original identity documents, passports or work permits must not be confiscated or retained to restrict their freedom;
• child labour must not be used and applicable minimum-working-age laws must be followed;
• wages, working hours, rest breaks, holiday and other conditions must comply with applicable law;
• threats, violence, intimidation, harassment, coercion and unlawful discrimination are prohibited;
• workers must have freedom of movement and the ability to raise concerns without retaliation; and
• subcontracting must not be used to conceal exploitation or avoid these standards.

4. Responsibilities

Senior management is responsible for supporting this policy and ensuring that proportionate processes are maintained. Managers are expected to remain alert to modern-slavery indicators, respond appropriately to concerns and avoid purchasing or operational practices that create unreasonable pressure or increase exploitation risks.

Everyone working for or on behalf of Stormspell must:

• read and comply with this policy;
• remain alert to possible signs of exploitation;
• report concerns promptly through the routes below;
• cooperate with relevant reviews or investigations; and
• never knowingly engage a person or organisation involved in modern slavery.

5. Recruitment and employment

Stormspell aims to maintain fair and lawful recruitment and employment practices. This includes confirming the right to work using lawful procedures, providing clear employment terms, paying wages through appropriate channels, not charging workers recruitment fees and respecting workers’ freedom to leave employment subject to lawful contractual notice.

Our induction and management awareness arrangements are intended to reinforce respectful conduct, equality, lawful working practices and the need to report possible exploitation. Any employee involved in recruitment or the management of temporary labour should pay particular attention to unusual payment arrangements, control by third parties, shared contact details, withheld documents or signs that a worker is being threatened or coerced.

6. Supplier due diligence

We take a proportionate, risk-based approach to suppliers and business partners. Depending on the nature, location and risk of the relationship, our checks may include:

• considering modern-slavery and labour risks when selecting or reviewing suppliers;
• asking suppliers to confirm their labour and human-rights standards;
• using supplier questionnaires, declarations or contractual expectations where appropriate;
• requesting a supplier’s modern-slavery statement, ethical policy, audit information or corrective-action plan;
• making further enquiries where products, countries, sectors, recruitment models or subcontracting arrangements present a higher risk;
• reviewing credible reports, concerns or adverse information; and
• requiring corrective action or ending a relationship where serious concerns are not addressed.

We do not expect suppliers to guarantee that every tier of a complex global supply chain is free from risk. We do expect transparency, cooperation, appropriate due diligence and prompt action when concerns arise.

7. Risk assessment

Modern-slavery risks are considered in proportion to our size, activities and supply-chain visibility. Factors that may increase risk include:

• manufacture or raw-material sourcing in countries or sectors associated with forced or child labour;
• extensive use of subcontracting, labour agencies or temporary labour;
• unusually low prices or delivery times that may place unlawful pressure on workers;
• limited supplier transparency or reluctance to answer reasonable questions;
• recruitment fees, debt arrangements or deductions from wages;
• workers appearing controlled, frightened, isolated or unable to speak freely; and
• accommodation, transport, bank accounts, identity documents or wages being controlled by another person.

A single indicator does not necessarily prove exploitation. Concerns must nevertheless be taken seriously and escalated safely.

8. Training and awareness

Relevant employees and managers should receive information appropriate to their roles, including how to recognise indicators, how supply-chain and recruitment risks can arise, and how to report a concern without putting a potential victim at further risk.

Modern-slavery awareness may be included within induction, management briefings, supplier-management processes and periodic policy communications. Additional guidance should be provided where a role involves recruitment, temporary labour, procurement or higher-risk suppliers.

9. Reporting a concern

Employees, suppliers and other parties should report any concern about possible modern slavery or a breach of this policy as soon as possible. Concerns may be raised with a line manager, a director or by contacting:

• Email: enl@stormspellroofing.co.uk
• Telephone: 01704 233 300
• Post: Stormspell Limited, Stormspell House, Russell Road, Southport, Merseyside PR9 7SB

Reports will be handled as sensitively as reasonably possible. Stormspell does not tolerate victimisation or retaliation against anyone who raises a genuine concern in good faith, even if an investigation does not ultimately confirm the concern.

If someone appears to be in immediate danger, call 999. Non-emergency concerns may be reported to the police on 101 or to the independent Modern Slavery & Exploitation Helpline on 08000 121 700. Care should be taken not to confront a suspected exploiter or take action that could increase risk to a potential victim.

10. Responding to concerns

When a concern is raised, Stormspell will consider the safety and welfare of any potential victim, preserve relevant information, obtain appropriate advice and refer the matter to law enforcement or a competent authority where necessary.

Where a concern involves a supplier, our response may include further enquiries, requesting evidence or corrective action, increasing monitoring, suspending new orders or terminating the relationship. The response will depend on the seriousness of the issue and the need to avoid unintended harm to affected workers.

11. Monitoring effectiveness

We aim to review the effectiveness of this policy and improve our approach over time. Proportionate measures may include monitoring:

• the number and outcome of concerns raised;
• completion of relevant awareness or training activity;
• the number of higher-risk suppliers assessed or asked for further information;
• supplier corrective actions and whether they are completed;
• any relationships suspended or ended because standards were not met; and
• changes made following incidents, reviews or new guidance.

These measures are intended to help Stormspell identify gaps, target action and demonstrate improvement rather than simply record whether a policy exists.

12. Breaches of this policy

A breach by an employee may result in disciplinary action, up to and including dismissal, in accordance with applicable procedures. A serious breach by a supplier, contractor or other business partner may result in corrective action, suspension or termination of the relationship and referral to the relevant authorities.

13. Review

This policy will be reviewed periodically and when there is a significant change to our business, supply chains, legal obligations or risk profile. Any formal annual modern-slavery statement required under section 54 will be reviewed, approved and signed separately for the relevant financial year.

Government guidance on modern-slavery reporting is available at GOV.UK.