Illegal Workers Policy¶
| Document Reference | POL_HSQE_17 |
|---|---|
| Revision | 3 |
| Issue Date | 1st July 2025 |
| Next Review | 1st July 2026 |
| Status | Uncontrolled when printed |
Purpose¶
A M Water Services Ltd maintains a zero-tolerance approach to employing illegal workers, ensuring we meet our legal obligations while protecting vulnerable individuals from exploitation and supporting ethical employment practices across our water services and grab operations.
Scope¶
This policy applies to all employees, directors, contractors, agency workers, subcontractors, work experience placements, and supply chain partners involved with A M Water Services Ltd.
Legal Requirements¶
This policy ensures compliance with the Immigration, Asylum and Nationality Act 2006, Immigration Acts 2014 and 2016, Modern Slavery Act 2015, Equality Act 2010, and Criminal Finances Act 2017.
Policy Statement¶
We are committed to preventing illegal working through robust verification procedures that protect both our business and vulnerable workers. Before any person begins work with us, whether directly employed, through an agency, or as a subcontractor, we verify their right to work in the UK using original documents, following Home Office guidance meticulously. This three-stage process involves checking documents before employment, taking verified copies on the first day, and monitoring any expiry dates throughout employment. We apply these checks fairly and consistently to avoid discrimination, ensuring everyone receives the same thorough verification regardless of their appearance, accent, or name.
Our commitment extends throughout our supply chain, particularly important given our work with multiple subcontractors on water infrastructure projects and grab operations. We require all agencies and subcontractors to provide evidence of their own right to work checks, with contractual provisions giving us the right to audit their compliance. When working on sensitive sites such as water treatment facilities or schools, these checks become even more critical to maintain our clients' trust and meet their safeguarding requirements.
Warning signs that might indicate illegal working include reluctance to provide documents, poor quality documentation, inconsistent information, multiple workers registered at the same address, or requests for cash payments. If we encounter any of these indicators, we investigate sensitively but thoroughly, recognizing that some situations may involve modern slavery or human trafficking. In such cases, our priority is ensuring the safety of potential victims while working with authorities including the Modern Slavery Helpline and Gangmasters and Labour Abuse Authority.
Implementation and Monitoring¶
Our Office Manager conducts all right to work checks, maintaining clear copies of documents with dates and verification details, storing records securely for at least two years after employment ends. Site supervisors receive training to recognize potential warning signs during their daily operations, particularly when managing agency workers or subcontractors. We conduct regular audits of our recruitment processes, current employee documentation, and supply chain compliance, with findings reported quarterly to the Directors.
Responsibilities¶
Directors hold overall responsibility for policy compliance and providing adequate resources for implementation. The Office Manager ensures all recruitment checks are completed properly and maintains accurate records. Site supervisors monitor compliance among workers on their sites and report any concerns immediately. All employees must cooperate with verification processes and report suspected breaches through our confidential reporting channels. Everyone in our #TEAM plays a vital role in maintaining our ethical standards and protecting vulnerable workers.
Review¶
This policy will be reviewed annually by the Directors to ensure it remains effective and continues to prevent illegal working while protecting vulnerable individuals across all company operations.
Signed:
Aaron Mason Director A M Water Services Ltd 1st July 2025
Local controlled copy
Word version of this controlled document (for offline / paper records):
The page above is the master source — the Word doc is a snapshot for offline use.