Our Aims and Commitment

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that FOWLC Comminity Interest Company (FOWLC) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. FOWLC has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

FOWLC is a new organisation founded for the purpose of delivering community leisure services and directed by experienced Board members with significant experience in operating leisure businesses. We are currently seeking to take over the operation of a single site leisure facility in the Wadebridge area of Cornwall.

Our Supply Chain

We will engage with a wide variety of organisations for the delivery of a broad range of goods and services.

Our supply chain partners vary in size and structure from very small locally sourced suppliers or contractors to large national corporate institutions.

We will encourage smaller businesses to join our supply chain as this accords with our desires to bring social and environmental benefits to the local communities in which we operate.

FOWLC are conscious that there are commercial, legal and safety related advantages to using suppliers who are able demonstrate compliance and competence and seeks to use external suppliers who share our values to maintain consistency of standards.

Where new suppliers are engaged they must successfully complete the FOWLC approved suppliers process. Our broad assessment criteria include checks of the following:

  1. Insurances
  2. Health & Safety documentation including Policy, Procedures, Risk Assessment and Method Statements
  3. Current quality accreditations or certifications e.g. ISO 9001, ISO 14001, OHSAS18001, CHAS IIP etc.
  4. Supplier credentials including qualifications, training and competency
  5. Customer references
  6. Details of any prosecutions, or notices for improvement

Contracts with suppliers to the facility will be reviewed in line with the above. As part of the contract review process we are introducing a contractual requirement for suppliers that they do not engage in any activity that is contrary to the Modern Slavery Act.

Policies and Procedures to Resist Modern Slavery and HUuman Trafficking

FOWLC will achieve these aims through our initiatives to identify and mitigate risk in the following ways (but not limited to):

  1. Stringent vetting of our supply chain through our approved supplier process and performance reviews;
  2. Continually review our practices for checking that all employees and apprentices are paid at least the living wage and have a right to work in the UK;
  3. Encourage the reporting of concerns and the protection of whistle blowers in line with ACAS guidance
  4. Will not knowingly support or deal with any business involved in modern slavery practices or human trafficking
  5. Have zero tolerance to slavery and human trafficking through colleague understanding of risks in our business, providing guidance to relevant managers and colleagues on the need to avoid those risks and possible indicators of them in the supply chain.
  6. Briefing Directors and managers on the risks and how these may arise within the business or supply chain.

In developing our internal policies and procedures we seek to ensure that we are conducting business in an ethical and transparent manner. The processes that we consider give us control in avoiding modern slavery or human trafficking under the act within our business are:

  1. Recruitment and Selection Procedure including guidance for the Prevention of Illegal working
  2. Equal Opportunities Policy
  3. Job offer Terms and Conditions of Employment
  4. Grievance Procedure
  5. New suppliers – companies procedure
  6. New suppliers – self-employed procedure
  7. Right to Work policy
  8. Equality and Diversity Policy
  9. Whistleblowing policy


This statement has been approved by the FOWLC Board of Directors and is made pursuant to section 54(1) of the Modern Slavery Act 2015

Document last updated: March 18th 2022

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