Introduction

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. It constitutes Clearway Disposals Limited slavery and human trafficking statement for the financial year ended 31st December 2018. This statement covers the activities of Clearway Disposals Limited in their procurement and supply of goods and services.

Organisation

Clearway Disposals Limited is one of the largest waste management companies in Northern Ireland. It operates three fully licenced/permitted metal recycling facilities based in Belfast, Derry and Portadown where its head office is also based. The company processes ferrous and non-ferrous metals which are then transported by road/sea steelworks and metal refineries to be recycled.

The company has approximately 110 employees who are mostly based in the United Kingdom. Staff are mainly full or part time permanent employees and are not in any category which is generally seen to be vulnerable to modern slavery in this country. As a result our focus is to ensure there are policies and procedures in place for our contractors and suppliers.

Supply Chain

Clearway Disposals Limited is committed to identifying and eliminating any slavery and human trafficking in its business and supply chains, and to always act ethically, professionally and with integrity in all its business relationships.

Policies

Clearway Disposals Limited have a number of policies which aim to minimise the risk of modern slavery which include:
Training Policy: Employees and management will receive ongoing training throughout their employment which includes staff awareness training on the Modern Slavery Act 2015.

Health and Safety Policy: This Policy ensures so far as reasonable and practicable the health safety and welfare of any person(s) who may be affected by Clearway Disposal Limited’s acts and omissions.

Temporary Staff Policy: Agencies used in the supply of workers must provide copies of certificates and any other reasonable information requested to satisfy Clearway Disposal Limited that they can legally carry out their duties.

Due Diligence Processes

Clearway Disposals Limited continues to monitor suppliers that could present high modern slavery risks in our supply chain. This includes suppliers of ferrous and non-ferrous scrap metals, suppliers of goods and services.

All suppliers which classed as high risk must complete the company’s Modern Slavery Act Due Diligence Questionnaire which covers their governance, policies, training and supply chain management processes.

Training

Throughout the course of employees and staff members employment the company will continually provide training through toolbox talks, external and in-house training by fully qualified instructors. All staff members with direct responsibility for relevant supply chains of goods and services have received and will receive ongoing refresher training on the Modern Slavery Act 2015 and a copy of which is made available on request.

Looking Ahead

Clearway Disposals Limited will continue to monitor the effectiveness of its policies and procedures throughout the year and will adopt any additional measures as deemed necessary following the identification of any evidence of breaches of the Modern Slavery Act 2015.

Directors and Management of the Clearway Group

March 2021