This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Surplex UK Limited’s (Surplex UK) slavery and human trafficking statement for the current financial year.

At Surplex UK, we are committed to acting ethically and with integrity in all our business dealings and relationships. We maintain a zero-tolerance approach to modern slavery, human trafficking, forced labour, and child labour. We are dedicated to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere within our own business or in any of our supply chains.

1. Organisational Structure and Supply Chains

Surplex UK operates within the Information Technology Asset Disposal (ITAD) and Waste Electrical and Electronic Equipment (WEEE) recycling sector. Our core operations include secure data destruction, IT hardware collection, and the ethical recycling and remarketing of redundant corporate technology.

Our primary supply chains include:

  • Downstream recycling partners and raw material refiners.
  • Logistics and fleet management providers.
  • Data destruction software vendors (e.g., Certus).
  • Facility management and operational equipment suppliers.

Given the global nature of the electronic waste industry, we recognise that the improper routing of e-waste poses a heightened risk of environmental exploitation and forced labour in developing nations. Therefore, we strictly control our downstream processing channels to mitigate these risks.

2. Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our anti-slavery stance is supported by internal policies that reflect our commitment to acting ethically, including:

  • Supplier Code of Conduct: Mandates that all third-party suppliers and contractors adhere to the standards set out in the Modern Slavery Act 2015.
  • Whistleblowing Policy: Encourages all employees, customers, and partners to report any concerns regarding unethical conduct, including modern slavery, without fear of retaliation.
  • Environmental and Ethical Disposal Policy: Ensures all WEEE is processed through audited, Environment Agency-approved channels, strictly prohibiting the illegal export of hazardous waste which can fuel unregulated, exploitative labour markets overseas.

3. Due Diligence Processes

To identify and mitigate risk within our supply chain, Surplex UK undertakes strict due diligence when onboarding new suppliers and downstream recycling partners. Our processes include:

  • Auditing Downstream Partners: We continuously monitor and audit our downstream WEEE processors to ensure they hold the necessary Environment Agency licenses and comply with UK environmental and labour laws.
  • Supplier Declarations: We require all major suppliers and contractors to formally agree to comply with all applicable anti-slavery and human trafficking laws.
  • Right to Work Checks: We conduct rigorous background and right-to-work checks on all Surplex UK employees to ensure compliance with UK employment legislation and to protect against forced labour.

4. Risk Assessment and Management

The ITAD and e-waste recycling industry carries inherent global risks, particularly concerning the illegal export of WEEE. Illegal e-waste dumping frequently intersects with unregulated labour markets and severe human rights abuses.

Surplex UK manages this risk by operating a strictly controlled, UK-centric processing model. By generating transparent audit trails, WEEE Waste Transfer Notes, and Certificates of Destruction for our clients, we ensure comprehensive accountability. We do not engage with brokers or unregistered third parties who cannot provide total transparency regarding their end-of-life material recovery processes.

5. Training and Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. All relevant personnel, particularly those in procurement, logistics, and compliance roles, are briefed on:

  • How to identify the signs of modern 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 regulatory bodies.

6. Board Approval

This policy is continually reviewed and updated to reflect our ongoing commitment to ethical business practices. Surplex UK will not support or deal with any business knowingly involved in slavery or human trafficking.

This statement has been approved by the Board of Directors of Surplex UK.