Anti-Modern Slavery Statement

1. Introduction

Imperial Security (“Imperial Security”, “the Company”, “we” or “our”) is a UK-based security services company headquartered at 152 City Road, London, EC1V 2NX. We provide a comprehensive portfolio of professional security services to businesses, organisations, and individuals throughout the United Kingdom, including but not limited to security guards, door supervision, event security, hotel and concierge security, corporate security, retail security, close protection bodyguards, educational security, construction site security, warehouse security, key holding, CCTV monitoring, mobile patrol, and night security services.

This Anti-Modern Slavery Statement (“the Statement”) is published by Imperial Security in accordance with Section 54 of the Modern Slavery Act 2015 (“the Act”) and sets out the steps we have taken, and continue to take, to ensure that modern slavery and human trafficking are not taking place within our business operations or our supply chains.

Imperial Security takes its legal and moral obligations under the Modern Slavery Act 2015 with the utmost seriousness. We recognise that modern slavery which encompasses slavery, servitude, forced and compulsory labour, and human trafficking is a grave violation of fundamental human rights. As a responsible employer operating within the private security industry, we are fully committed to acting ethically and with integrity in all our business activities and to implementing and enforcing effective systems and controls to safeguard against any form of modern slavery or human trafficking.

This Statement covers the financial year 2025 to 2026 and should be read in conjunction with our Privacy Policy, Equality and Diversity Policy, and our Supplier Code of Conduct.

2. About Imperial Security

Imperial Security is one of the leading licensed and accredited security service providers operating throughout London and the wider United Kingdom. Our registered office is situated at 152 City Road, London, EC1V 2NX. We operate under the rigorous oversight of the Security Industry Authority (“the SIA”), and all of our frontline security operatives are fully SIA-licensed, rigorously vetted, and extensively trained to the highest professional standards in the private security industry.

As a responsible employer, we deploy security personnel across a diverse range of sectors, including commercial, corporate, retail, hospitality, education, events, construction, warehousing, and the public sector. Our operations span across the entirety of the United Kingdom, with deep roots in central London.

2.1 Our Services

Imperial Security provides the following professional security services:

• Security Guards fully licensed, vetted, and trained manned guarding services for all sectors
• Door Supervision professional access control and crowd management for licensed venues
• Event Security comprehensive security for public and private events, festivals, film sets, and exhibitions
• Hotel & Concierge Security discreet guest safety and emergency response for the hospitality sector
• Corporate Security protecting business offices, banks, and commercial properties
• Retail Security loss prevention, shoplifting deterrence, and asset safety
• Close Protection Bodyguards personal security for executives, high-profile individuals, and families
• Educational Security safeguarding schools, colleges, and universities
• Construction Site Security protecting assets and ensuring safety compliance on building sites
• Warehouse Security safeguarding day and night operations for logistics and distribution
• Key Holding secure key storage and 24/7 emergency response
• CCTV Monitoring vigilant remote monitoring services
• Mobile Patrol Security flexible, cost-effective mobile patrol coverage
• Night Security dedicated overnight protection services
• Relief Security Guards flexible cover for planned and emergency absences
• Crowd Management Services specialist crowd control and stewarding

2.2 Our Workforce

Our workforce comprises directly employed security operatives, support staff, and management personnel. All security personnel are required to hold a valid SIA licence prior to deployment. We are committed to ensuring that every individual working within our organisation, at every level, is treated with dignity, respect, and fairness, and that their fundamental rights are upheld at all times.

3. Legal and Regulatory Framework

The Modern Slavery Act 2015 is the principal piece of UK legislation addressing modern slavery and human trafficking. The Act consolidates and simplifies existing offences relating to trafficking and slavery, provides enhanced powers to tackle these crimes, and introduces a range of measures to support victims and bring perpetrators to justice.

Section 54 of the Act requires commercial organisations with an annual turnover of £36 million or more to publish an annual slavery and human trafficking transparency statement. Whilst Imperial Security may not currently meet this financial threshold, we voluntarily publish this Statement as a demonstration of our unwavering commitment to combating modern slavery in all its forms and to operating transparently and responsibly.

In addition to the Modern Slavery Act 2015, Imperial Security also operates in accordance with, and has regard to, the following relevant legislation and guidance:

• The Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015
• The Criminal Justice (Scotland) Act 2003
• The Gangmasters (Licensing) Act 2004 and associated regulations
• The National Referral Mechanism (NRM) framework for identifying and supporting victims of modern slavery
• The Home Office ‘Transparency in Supply Chains’ statutory guidance
• The Security Industry Authority’s licensing and compliance requirements
• The Employment Rights Act 1996 and associated employment legislation
• The Equality Act 2010
• The National Minimum Wage Act 1998 and associated regulations

4. Our Policies in Relation to Modern Slavery

Imperial Security maintains a robust framework of internal policies designed to prevent modern slavery, human trafficking, and related exploitation within our operations and supply chains. Our policies reflect our commitment to acting ethically, lawfully, and with integrity in all our business dealings.

4.1 Anti-Modern Slavery and Human Trafficking Policy

Our dedicated Anti-Modern Slavery and Human Trafficking Policy sets out our zero-tolerance approach to all forms of modern slavery and human trafficking. The Policy defines the relevant offences, explains how they may arise within the security industry, and sets out the responsibilities of all staff in identifying and reporting concerns. The Policy is reviewed annually and updated in line with legislative changes and best practice guidance.

4.2 Recruitment and Employment Policy

Our Recruitment and Employment Policy establishes robust procedures to ensure that all individuals we employ have the legal right to work in the United Kingdom, are engaged on lawful and transparent terms, and are not subject to any form of coercion, debt bondage, or forced labour. These procedures include:

• Verification of the right to work in the UK for all employees and agency workers prior to engagement
• Checking original identity documents and maintaining copies in accordance with Home Office guidance
• Ensuring that all employment contracts are written, clear, and signed by both parties
• Confirming that all workers are paid at least the National Living Wage or National Minimum Wage, as applicable
• Ensuring that no unlawful deductions are made from wages
• Confirming that accommodation provided to workers, where applicable, meets appropriate standards and is not used as a means of control
• Prohibiting the retention of workers’ passports, identity documents, or any other personal documents

4.3 Whistleblowing Policy

Our Whistleblowing Policy encourages and enables employees, contractors, and third parties to report, in good faith, any concerns about suspected modern slavery, human trafficking, labour exploitation, or other wrongdoing within our business or supply chains, without fear of retaliation or victimisation. All reports are treated with the utmost confidentiality and are investigated thoroughly and promptly.

Individuals who raise concerns in good faith will be protected from any form of detriment, and we are committed to taking appropriate action in response to any concerns raised.

4.4 Supplier Code of Conduct

Our Supplier Code of Conduct sets out the standards of ethical conduct that we require all of our suppliers, subcontractors, and business partners to adhere to. These standards include a requirement to comply with all applicable anti-slavery and human trafficking laws, to operate ethical recruitment practices, to pay workers lawfully and in a timely manner, and to treat all workers with dignity and respect.

4.5 Equal Opportunities and Dignity at Work Policy

Our Equal Opportunities and Dignity at Work Policy reflects our commitment to treating all individuals fairly, regardless of their background, nationality, or personal circumstances. We operate a zero-tolerance approach to discrimination, harassment, and bullying of any kind.

5. Due Diligence Processes

Imperial Security undertakes a range of due diligence processes to identify and address the risk of modern slavery and human trafficking within our business and supply chains. These processes are reviewed and updated on an ongoing basis to ensure that they remain effective and proportionate.

5.1 Employee Vetting and Screening

All individuals engaged by Imperial Security undergo a thorough pre-employment vetting and screening process prior to commencement of employment. This process is designed not only to ensure compliance with SIA licensing requirements and security industry standards but also to identify any indicators of modern slavery or labour exploitation. Our vetting and screening process includes:

• Verification of identity through original photographic documentation
• Right to work checks in accordance with Home Office guidance and the Immigration, Asylum and Nationality Act 2006
• Disclosure and Barring Service (DBS) criminal records checks at the appropriate level
• Five-year employment history verification
• Confirmation of current address and residential history
• Reference checks with previous employers
• SIA licence verification through the official SIA licence checker
• Where applicable, checks to identify individuals who may have been subject to trafficking or exploitation

5.2 Supply Chain Due Diligence

Imperial Security operates within a supply chain that includes, amongst others, recruitment agencies, subcontracted security personnel, uniform and equipment suppliers, and training providers. We recognise that supply chains can present a risk of modern slavery and labour exploitation, and we take our responsibility to address this risk seriously.

Our supply chain due diligence processes include:

• Pre-contract screening and assessment of all new suppliers and subcontractors, including a review of their own anti-slavery policies and practices
• Inclusion of anti-slavery and human trafficking clauses within supplier contracts and subcontractor agreements
• Annual self-assessment questionnaires issued to key suppliers to monitor ongoing compliance
• Periodic site visits and audits of high-risk suppliers, where appropriate
• Immediate termination of supplier relationships where evidence of modern slavery or human trafficking is identified
• A preference for suppliers who are members of relevant industry bodies and who hold appropriate accreditations and certifications

5.3 Subcontracted Security Personnel

Where Imperial Security engages subcontracted security personnel through third-party agencies or sole traders, we require all subcontractors to demonstrate that their workers hold valid SIA licences, have been lawfully recruited, and are engaged on appropriate terms. We apply the same vetting standards to subcontracted personnel as we do to directly employed staff.

6. Risk Assessment and Management

Imperial Security acknowledges that certain aspects of the private security industry can present elevated risks of modern slavery and labour exploitation. We have conducted a risk assessment of our operations and supply chains in order to identify areas of higher risk and to direct our due diligence efforts accordingly.

6.1 Identified Risk Areas

Our risk assessment has identified the following areas as presenting a higher risk of modern slavery within the security industry:

• Casual and agency recruitment the use of third-party recruitment agencies and self-employed operatives may increase the risk of workers being subject to coercion or exploitation
• Overseas recruitment the recruitment of workers from outside the UK can present a higher risk of exploitation, debt bondage, and trafficking
• Uniform, equipment, and merchandise supply chains global supply chains for uniforms, equipment, and other goods may involve subcontracted manufacturing in jurisdictions with less robust labour protections
• Workers in vulnerable circumstances individuals with limited English language skills, irregular immigration status, or limited awareness of their rights may be at greater risk of exploitation
• High-turnover and low-wage roles frontline security roles may attract individuals who are vulnerable to exploitation due to financial pressures

6.2 Risk Mitigation Measures

In response to our risk assessment, Imperial Security has implemented the following risk mitigation measures:

• Enhanced due diligence for recruitment agencies and subcontractors operating in higher-risk areas
• Regular training for managers and HR staff on identifying indicators of modern slavery and exploitation
• Maintaining an open-door policy that encourages workers to raise concerns freely and without fear
• Conducting regular welfare checks with operatives to identify any signs of distress, coercion, or exploitation
• Ensuring all workers are informed of their rights, including their right to a written employment contract, their right to the National Minimum Wage, and their right to seek support if they believe they are a victim of modern slavery
• Preference for UK-based suppliers with transparent supply chains and robust compliance frameworks

7. Training and Awareness

Imperial Security recognises that the effective prevention of modern slavery requires all members of our organisation to be equipped with the knowledge and skills necessary to identify and respond to indicators of exploitation. We invest in ongoing training and awareness-raising as a core component of our anti-slavery strategy.

7.1 Staff Training

All new employees receive training on modern slavery and human trafficking as part of their induction programme. This training covers:

• A clear definition of modern slavery and its various forms, including slavery, servitude, forced and compulsory labour, and human trafficking
• Common indicators and warning signs that an individual may be a victim of modern slavery or exploitation
• How to respond appropriately and sensitively if a concern is identified
• How to make a referral under the National Referral Mechanism (NRM)
• Imperial Security’s internal reporting procedures and the protections available to those who raise concerns
• Relevant legislation and the consequences of non-compliance

7.2 Managers and Supervisors

Managers, supervisors, and HR professionals receive enhanced training on modern slavery, including guidance on identifying exploitation during the recruitment process, conducting welfare checks, and managing disclosures sensitively and appropriately. Managers are also trained to recognise the indicators of labour trafficking and to take prompt and decisive action where concerns arise.

7.3 Awareness Campaigns

Imperial Security supports national and industry-wide awareness campaigns on modern slavery and human trafficking, including those led by the Home Office, the Gangmasters and Labour Abuse Authority (GLAA), and the Security Industry Authority. We display relevant information and helpline details in prominent locations within our premises and on our internal communications platforms.

8. Reporting Concerns and Supporting Victims

8.1 Internal Reporting

Any employee, worker, contractor, or third party who suspects or becomes aware of any form of modern slavery, human trafficking, or labour exploitation within our business or supply chains is encouraged and expected to report their concerns immediately. Reports can be made to a line manager, senior manager, or directly to the HR department. Concerns can be raised verbally or in writing, and where individuals prefer, they may raise concerns anonymously through our confidential reporting channel.

All reports of suspected modern slavery are investigated promptly, thoroughly, and in strict confidence. Imperial Security will not tolerate any form of retaliation against individuals who raise concerns in good faith.

8.2 Statutory Referral Mechanisms

Where we have reasonable grounds to believe that an individual may be a victim of modern slavery or human trafficking, Imperial Security is committed to making a referral under the National Referral Mechanism (NRM) without delay. The NRM is the UK’s framework for identifying and supporting victims of modern slavery and human trafficking.

Where there is an immediate risk to the safety of an individual, we will contact the emergency services without delay. We will also cooperate fully with the police, the Gangmasters and Labour Abuse Authority (GLAA), the Home Office, and any other relevant statutory authorities in the investigation of modern slavery offences.

8.3 Support for Victims

Imperial Security is committed to treating any individual who may be a victim of modern slavery with dignity, sensitivity, and compassion. We will take all reasonable steps to ensure that victims are referred to appropriate support services, including the Modern Slavery Helpline, the Salvation Army, and other specialist victim support organisations.

Key support contacts are as follows:

• Modern Slavery Helpline: 0800 0121 700 (24 hours, 7 days a week, free to call)
• National Crime Agency Modern Slavery Intelligence Unit: www.nationalcrimeagency.gov.uk
• Gangmasters and Labour Abuse Authority (GLAA): 0800 432 0804
• Crimestoppers (anonymous reporting): 0800 555 111
• Emergency Services: 999

9. Key Performance Indicators

In order to assess the effectiveness of our efforts to combat modern slavery and human trafficking, Imperial Security monitors the following key performance indicators (KPIs) on an ongoing basis:

• Percentage of employees who have completed modern slavery awareness training
• Number of concerns or disclosures received and investigated during the financial year
• Number of referrals made under the National Referral Mechanism (NRM)
• Percentage of suppliers and subcontractors who have completed our anti-slavery self-assessment questionnaire
• Number of supplier audits and site visits conducted
• Number of supplier relationships terminated due to non-compliance with our Supplier Code of Conduct
• Regular review and update of all relevant internal policies

The results of our KPI monitoring are reviewed annually by senior management and are used to inform continuous improvement of our anti-slavery programme.

10. Our Commitments and Future Steps

Imperial Security is committed to continuously improving our approach to combating modern slavery and human trafficking. In the coming financial year, we commit to taking the following additional steps to strengthen our anti-slavery programme:

• Review and update all internal anti-slavery and human trafficking policies to ensure that they reflect the latest legislative requirements and best practice guidance
• Expand our modern slavery training programme to include all levels of the organisation, with a particular focus on frontline security operatives who may be best placed to identify indicators of exploitation in the field
• Implement a formal supplier risk-rating system to prioritise due diligence efforts in higher-risk areas of our supply chain
• Develop and publish a dedicated Modern Slavery Resource Pack for all employees, providing clear guidance on identifying and reporting concerns
• Engage with industry bodies, including the Security Industry Authority and the British Security Industry Association (BSIA), to share best practice and contribute to sector-wide efforts to combat modern slavery
• Review and strengthen our whistleblowing procedures to ensure that they are accessible, effective, and understood by all members of our workforce
• Explore the use of technology-based solutions to enhance supply chain transparency and identify potential risks more effectively

11. Governance and Responsibility

Responsibility for our anti-slavery and human trafficking programme sits at the most senior level of Imperial Security’s management team. Our Director holds ultimate responsibility for ensuring that this Statement is accurate, up to date, and that our anti-slavery policies and procedures are implemented effectively throughout the organisation.

Our Human Resources and Compliance teams are responsible for the day-to-day oversight of our anti-slavery programme, including the management of training, supplier due diligence, and the investigation of reported concerns.

This Statement is reviewed and approved annually by senior management and is published on our website at www.imperialsecurity.agency in accordance with the requirements of the Modern Slavery Act 2015.