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Modern Slavery Act 2015

Pure Klass Cleaning

Modern Slavery Statement 2024


Modern Slavery Statement

This statement is made as part of Pure Klass Cleaning Ltd’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act), to understand all potential modern slavery risks related to its business and to put in p.lace steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year to 31 March 2021.

Pure Klass Cleaning Ltd recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

1. Our business

Pure Klass Cleaning is a limited company operating in the Commercial Cleaning sector. Our business consists of cleaning properties and accommodation in both the private and public sectors. We recruit from the UK and Europe where we have a mix of temporary and permanent workers.

Pure Klass Cleaning Ltd is an independent business.

1.1. Who we work with

All of the workers we hire on a temporary or permanent basis are known to and identified by our staff. A thorough background vetting takes place including a DBS check before work commences and a worker is allowed on site.

The hiring companies of our workers are located in various locations across the UK. The workers undertaking the necessary cleaning duties we supply live in locations local to the clients we are working with or we offer suitable transport.

2. Our policies

Pure Klass Cleaning Ltd has a modern slavery policy.

In addition, Pure Klass Cleaning Ltd has the following policies which incorporate ethical standards for our staff and our suppliers.

  • Whistleblowing policy. The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

  • Employee code of conduct. The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating nationally, internationally and managing its supply chain.

  • Supplier code of conduct. The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.

2.1 Policy development and review

Pure Klass Cleaning Ltd’s policies are established by our directors and senior management team based on advice from HR professionals, industry best practice and legal advice. We review our policies annually or as needed to adapt to changes.

3. Our processes for managing risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

When engaging with suppliers, where available, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing. When engaging with any new recruit they need to pass our pre-employment checks with verified right to work documentation, identification and qualifications.

  • We conduct paper audits before entering into a commercial relationship with any business where there is the potential for risk.

  • We review the potential for risk at regular intervals.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our workforce or businesses we supply to. However, we continue to be alert to the potential for problems.


Additionally, we have taken the following steps to minimise the possibility of any problems:

  • We reserve the right to conduct spot-checks of the businesses or staff we work with, in order to investigate any complaints.

  • We require the businesses we work with to abide by our code of supplier conduct and address modern slavery concerns in their policies.

  • Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships.

  • Our staff are encouraged to bring any concerns they have to the attention of senior management.

4. Our training

All of our staff receive training and support that is appropriate to their role. In particular:

  • Our cleaning staff, recruiters, HR professionals and the senior management team who are involved in our procurement and supply chains undertake training that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.

The organisations modern slavery training covers:

  • Our business’s negotiating practices, which influence supply chain staffing, and which should therefore prevent the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;

  • How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

  • How to identify the signs of slavery and human trafficking;

  • What initial steps should be taken if slavery or human trafficking is suspected;

  • How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;

  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and government guidelines.

  • What steps the organisation should take if its business partners do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Training is reviewed annually.

As well as initial training staff, Pure Klass Cleaning will raise awareness of modern slavery issues by circulating a series of emails to staff.

Signed by the Managing Director


Moses Opone

23rd January 2024

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