Modern Slavery Policy

Modern Slavery and Human Trafficking Policy

Tmahanaim Ltd  |  Version 1.0  |  Effective Date: 12/02/2026

 

Organisation:	Tmahanaim Ltd
Policy Owner:	Olatunji Jaiyeola, Director
Effective Date:	12/02/2026
Review Date:	12/02/2027
Version:	1.0

 

1. Purpose and Scope

Tmahanaim Ltd is committed to acting ethically and with integrity in all of its business activities and to implementing effective controls to ensure that modern slavery and human trafficking do not occur within the organisation or in connection with its operations.

This policy applies to all individuals working for or on behalf of Tmahanaim Ltd in any capacity, including employees, workers, and volunteers. It sets out the organisation’s position, responsibilities, and approach to preventing modern slavery and human trafficking in accordance with the Modern Slavery Act 2015.

Tmahanaim Ltd acknowledges that, as an organisation with a current turnover below the statutory £36 million threshold, it is not legally required to publish an annual transparency statement under Section 54 of the Modern Slavery Act 2015. Notwithstanding this, the organisation has voluntarily adopted this policy in recognition of its responsibilities as an ethical employer and as a supplier to public sector contracting authorities.

 

2. Our Position

Tmahanaim Ltd has a zero-tolerance approach to modern slavery and human trafficking in any form. Modern slavery encompasses slavery, servitude, forced or compulsory labour, and human trafficking — all serious violations of fundamental human rights that Tmahanaim Ltd will not tolerate in any part of its operations.

The organisation is committed to ensuring that all workers engaged by Tmahanaim Ltd are treated with dignity and respect, are employed lawfully and fairly, and are free to leave their employment without penalty or coercion.

 

3. Organisational Structure, Business and Operations

Tmahanaim Ltd is a small, UK-based wood waste management business with a current workforce of between one and five employees. All services are delivered directly by Tmahanaim Ltd personnel without the use of subcontractors. All operations take place within the United Kingdom.

The organisation’s activities involve the collection, processing, treatment, and disposal of wood waste, including manual handling and site-based operations. Given its small size and direct employment model, the organisation’s exposure to modern slavery risk is considered low. However, Tmahanaim Ltd recognises that manual and physical labour roles can in some circumstances attract vulnerable individuals, and takes its responsibilities in this area seriously and proactively.

 

4. Risk Assessment

Tmahanaim Ltd has considered the modern slavery risks most relevant to its size, structure, and operational activities. The key risk areas identified are:

• Manual and physical handling roles, which may attract economically vulnerable workers who could be at risk of exploitation by third parties.
• Recruitment and labour sourcing, where there is a risk that unscrupulous recruiters may seek to place trafficked, coerced, or otherwise exploited workers.
• Future supply chain relationships, should subcontractors, labour providers, or suppliers be engaged in the future, which may introduce additional labour risk not currently present in Tmahanaim Ltd’s operations.

 

These risks are considered low given the organisation’s current direct employment model and small workforce. Risk assessments will be reviewed annually and updated as necessary to reflect any changes in the organisation’s structure, workforce, or future supply chain arrangements.

 

5. Prevention Procedures

Tmahanaim Ltd has implemented the following controls to prevent modern slavery within its operations:

• All workers are employed by Tmahanaim Ltd under written contracts of employment that clearly set out their rights, remuneration, working hours, and terms of engagement.
• All workers are paid at least the National Living Wage or National Minimum Wage applicable to their age and circumstances. Wages are paid directly to each individual’s nominated bank account.
• No worker is required to pay any fee, deposit, or charge in connection with their employment or continued engagement with Tmahanaim Ltd.
• Workers retain full control of their own identity documents at all times. No documents are held, retained, or withheld by the organisation.
• Workers are free to leave their employment at any time in accordance with their contractual notice period, without penalty or coercion.
• Recruitment is conducted through lawful and transparent means. Right-to-work checks are conducted for all new employees in accordance with current UK legislation.
• All workers are made aware of this policy, their rights, and how to raise concerns at the point of induction and on an ongoing basis.

 

6. Due Diligence

Tmahanaim Ltd currently delivers all services directly and does not use subcontractors or labour providers. As a result, the risk of modern slavery in the organisation’s supply chain is minimal at this time.

Should Tmahanaim Ltd engage any subcontractors, suppliers, or labour providers in the future, the following due diligence measures will be applied before and during engagement:

• Assessment of the prospective supplier’s or subcontractor’s own modern slavery policy, procedures, and labour practices prior to engagement.
• Verification that all workers engaged by the supplier or subcontractor are employed lawfully and treated in accordance with applicable employment and human rights legislation.
• Inclusion of contractual clauses requiring compliance with the Modern Slavery Act 2015 and this policy as a condition of engagement.
• Ongoing monitoring of supplier and subcontractor practices, with the right to audit and to terminate relationships where non-compliance is identified.

 

7. Training and Awareness

All employees of Tmahanaim Ltd receive modern slavery awareness training as part of their induction programme and on a refresher basis at least annually. Training covers, as a minimum:

• What modern slavery is and the different forms it can take, including forced labour, debt bondage, domestic servitude, and human trafficking.
• The scale and prevalence of modern slavery in the UK, including its relevance to the waste management and manual handling sectors.
• Key legislation, including the Modern Slavery Act 2015 and related criminal offences.
• The National Referral Mechanism (NRM) — what it is, how it works, and the support available to potential victims.
• The physical, psychological, and behavioural signs that may indicate a person is a victim of modern slavery or trafficking.
• Internal reporting procedures and external escalation routes, including the Modern Slavery Helpline (0800 0121 700).

 

Training completion is recorded and maintained by the Policy Owner. Training materials are reviewed and updated in line with legislative or guidance changes.

 

8. Raising and Reporting Concerns

Tmahanaim Ltd encourages all workers to raise any concerns about modern slavery or suspected exploitation — whether relating to themselves, a colleague, or any individual encountered in connection with the organisation’s operations.

Concerns may be raised with the Director / Policy Owner directly, verbally or in writing. All concerns will be treated seriously, investigated promptly, and handled with appropriate confidentiality. No worker will suffer any detriment or retaliation for raising a concern in good faith.

Where there are reasonable grounds to believe that a person is a victim of modern slavery or trafficking, Tmahanaim Ltd will report this to the relevant authorities without delay, including by contacting the Modern Slavery Helpline on 0800 0121 700 or calling 999 in an emergency.

 

9. Responsible Person

Overall responsibility for this policy and for Tmahanaim Ltd’s approach to preventing modern slavery rests with the Director. The responsible person is accountable for:

• Ensuring this policy is communicated to and understood by all staff.
• Overseeing the delivery and recording of modern slavery training.
• Receiving, investigating, and acting on any concerns raised under this policy.
• Conducting the annual policy review and updating the policy as necessary.
• Reporting on modern slavery matters to any contracting authority upon request.

 

Responsible Person:	Olatunji Jaiyeola
Title:	Director, Tmahanaim Ltd
Contact:	Info@tmahanaim.com
Phone:	07868771570

 

10. Monitoring and Review

This policy will be reviewed by the Director at least annually, or sooner in the event of:

• A material change in the organisation’s workforce, structure, or supply chain arrangements.
• A concern, allegation, or incident relating to modern slavery being raised or identified.
• A relevant change in legislation, regulatory guidance, or published best practice.

 

Tmahanaim Ltd is committed to strengthening and developing this policy as the organisation grows, and to publishing a full statutory Modern Slavery and Human Trafficking Statement under Section 54 of the Modern Slavery Act 2015 should the relevant statutory threshold be reached.

 

Policy Authorisation

Authorised by:	Olatunji Jaiyeola
Title:	Director, Tmahanaim Ltd
Date:	12/02/2026
Signature:	OLATUNJI JAIYEOLA