Modern slavery statement

This statement

This statement is made by Refreshment Systems Limited (RSL) for the financial year ending 31st March 2026. It sets out the actions and controls we have implemented across our UK operations and global supply chains to prevent modern slavery and human trafficking.

Although RSL’s annual turnover of £14.5M places us as a Small and Medium Enterprise (SME) below the statutory mandatory threshold of £36M under Section 54 of the Modern Slavery Act 2015, we operate a strict zero-tolerance approach to modern slavery. We voluntarily adhere to full transparency standards, ensuring our commercial partners, public sector clients, and facilities management (FM) contractors receive complete auditability.

Our business

Refreshment Systems Limited supplies, installs, and services commercial coffee machines, vending equipment, and water dispensers for workplaces across the United Kingdom. Operating from our head office at 31 Bolling Road, Bradford (BD4 7HN), we manage a dedicated national network of field service engineers, operating hubs, and delivery fleets servicing corporate, healthcare, education, and retail environments.

All members of our workforce are directly employed in the UK, subject to strict right-to-work verification and ethical employment standards.

Our supply chains

Our supply chains span multi-tier manufacturing and agricultural sourcing across direct and indirect tiers (Tiers 1–5):

• Machine Manufacture: Commercial vending and coffee machinery sourced from primary manufacturing locations in Europe (including Italy, Switzerland, and Germany) and Asia (China).
• Ingredients & Consumables: Agricultural commodities including coffee beans, tea, and cocoa, alongside vending milks, sugar, syrups, and paper/plastic cups.
• Logistics & Warehousing: UK-wide freight, local courier distribution, and regional stockholding hubs.
• Facilities & Premises Services: Specialist third-party cleaning, site security, and contractor services at RSL premises.

Policies

• RSL enforces a robust suite of governance policies approved by senior management:
• Anti-Slavery Policy Statement: Re-issued and signed by our Director on 23rd March 2026, establishing zero-tolerance prohibitions on forced labour, debt bondage, or child labour across all suppliers and tiers.
• Whistleblowing & Grievance Policy: Protects employees, agency workers, and third parties raising concerns about unethical practices or modern slavery suspicions, guaranteeing protection against detrimental treatment or retaliatory action.
• Supplier Code of Conduct & Onboarding Standards: Requires all new and existing suppliers to complete mandatory evaluation forms annually, accepting our anti-slavery principles.
• Recruitment & Ethical Employment Policy: Mandatory right-to-work document checks prior to candidate onboarding, prohibiting worker-paid recruitment fees, document confiscation, or compulsory overtime. — right-to-work checks on every hire.

Due diligence

• Supplier Due Diligence
• Pre-Contract Screening: 100% of new suppliers are evaluated on labour standards and human rights compliance during onboarding.
• Active NGO Collaboration: RSL actively partners with Stop the Traffik to strengthen supply chain risk assessment frameworks and elevate operational awareness.
• Audit Protocols: Supplier evaluations and social/labour condition audits are conducted annually across Tier 1 and high-risk tiers.

9-Step Incident Response Protocol

RSL maintains a formal 9-step action process (signed off by Director Steve May on 5th January 2026) for responding to any reported or suspected instances of modern slavery:

1. Immediate Acknowledgment & Confidential Record: Logging reports while protecting whistleblower anonymity.
2. Preliminary Assessment: Initial review to assess credibility and scope.
3. Multidisciplinary Investigation Team: Assembling internal HR, Commercial, Operations, or Director leads (and external legal experts where required).
4. Discreet Investigation: Gathering evidence respectfully while preserving confidentiality.
5. Victim Safeguarding & Interim Action: Immediate removal of vulnerable individuals from harm and suspension of implicated supplier contracts if needed.
6. Response Plan Formulation: Addressing root causes and structuring corrective measures.
7. Corrective Action & Victim Support: Providing counselling, legal support, or alternative placement assistance.
8. Internal & External Reporting: Escalating findings to senior leadership, law enforcement, or relevant industry bodies.
9. Continuous Monitoring & Review: Updating policies and training to prevent future occurrence.

Risk assessment

RSL assesses modern slavery risks across country, sector, and commodity tiers:

• Inherent High-Risk Areas: Agricultural production of raw coffee beans, tea, and cocoa, as well as component manufacturing in high-risk regions (e.g., China, Brazil, Vietnam). RSL mitigates these risks by favoring ethical sourcing schemes and requiring direct suppliers to demonstrate Tier 2+ visibility.
• Inherent Low-Risk Areas: Direct UK operations, field engineering services, and UK warehousing, where direct employment and strict statutory HR checks apply.

Measuring effectiveness

In August 2026, RSL completed the Modern Slavery Assessment Tool (MSAT) through the Government Supplier Registration Service. Our assessment report recorded an overall score of 98% (Green Rating) across all evaluated operational themes:

Theme

Rating & Score

Status

Governance

Green (100%)

Fully Compliant

Policies & Procedures

Green (100%)

Fully Compliant

Risk Assessment & Management

Green (100%)

Fully Compliant

Due Diligence

Green (92%)

Active Monitoring

Training

Green (100%)

Fully Compliant

Key Performance Indicators (KPIs)

Green (100%)

Fully Compliant

Key Performance Metrics Tracked Annually

• 100% of business units and supply chain entities covered by modern slavery policies.
• 100% of core suppliers screened for modern slavery risks annually during onboarding/evaluation.
• 100% of new employee hires receiving modern slavery awareness training during induction within their first month.
• 0 recorded modern slavery incidents or breaches within RSL operations or direct supply chains over the past 12 months.

Training

• Induction Training: Modern slavery awareness and indicators (aligned with ILO Forced Labour Indicators) are mandatory for all new hires during onboarding.
• Targeted Roles: Enhanced training is provided to employees in Purchasing, Commercial, HR, Operations, and Recruitment to equip them to identify risks during procurement and supplier engagement.
• Supplier Guidance: RSL works with key suppliers to align training standards and promote a unified approach to combating human trafficking.

Approval

This statement was formally approved by the senior management and Board of Directors of Refreshment Systems Limited and is signed on their behalf by:

Steven May

Director, Refreshment Systems Limited

Date: 26th August 2026

Downloads & compliance evidence

You can download signed PDF copies of our full policy documentation and assessment reports directly below:

• 📄 Download Anti-Slavery Policy Statement (PDF) (opens in a new tab) (Signed 23rd March 2026 by Director)
• 📄 Download Modern Slavery Response & Action Process (PDF) (opens in a new tab) (Signed 5th January 2026 by Steven May, Director)
• 📄 Download Cabinet Office / NQC Modern Slavery Assessment Report 2026 (PDF) (opens in a new tab) (Full 20-page audit report — Score: 98% Green)