Modern Slavery and Human Trafficking Policy​

1. Our commitment

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Ecoaera Limited is committed to conducting business ethically, responsibly and with respect for human rights. We have a zero tolerance approach to modern slavery, human trafficking, forced labour, servitude, child labour and exploitation within our business and supply chain. We will take reasonable and proportionate steps to identify, prevent and respond to modern slavery risks connected with our activities.

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2. Voluntary statement

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Section 54 of the Modern Slavery Act 2015 requires certain organisations with annual turnover of at least £36 million to publish an annual modern slavery statement. Ecoaera Limited does not currently meet this threshold and is not legally required to publish a statement. We have chosen to publish this policy voluntarily to demonstrate our commitment to ethical working practices and responsible supplier management.

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3. About Ecoaera

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Ecoaera Limited provides secure IT equipment recycling, IT asset disposal and data destruction services to organisations in England.

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Our activities may include:

• Collecting and transporting IT equipment
• Asset recording and auditing
• Secure data erasure and physical destruction
• Preparing suitable equipment for reuse
• Recycling equipment and materials
• Providing customer reports and certificates

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Our suppliers and partners may include:

• Collection and logistics providers
• Waste carriers
• Recycling and recovery facilities
• Data destruction providers
• Equipment reuse and resale partners
• Technology and software providers
• Professional and facilities service providers

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4. Our standards

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Ecoaera will not knowingly work with any person or organisation involved in modern slavery or human trafficking.

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We expect everyone working for us or on our behalf to:

• Comply with applicable employment and human rights laws
• Ensure work is undertaken voluntarily
• Provide lawful pay and working conditions
• Not use forced, trafficked or child labour
• Not unlawfully withhold wages or identity documents
• Not charge workers unlawful recruitment fees
• Treat workers fairly and with dignity
• Allow concerns to be raised without retaliation

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These expectations apply to employees, contractors, suppliers, subcontractors and business partners.

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5. Supplier checks

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We will take a proportionate approach to checking suppliers and partners.

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Depending on the nature and risk of the service, checks may include:

• Confirming the supplier’s identity and business details
• Checking relevant licences, permits and registrations
• Reviewing modern slavery policies or statements
• Asking about employment and subcontracting arrangements
• Reviewing the supplier’s reputation and business practices
• Requesting information about downstream partners
• Obtaining appropriate contractual commitments

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Additional checks may be carried out where a supplier operates in a higher risk sector or relies heavily on temporary, migrant or subcontracted labour.

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6. Areas of risk

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We recognise that modern slavery risks may be higher within:

• Transport and logistics
• Warehousing and waste processing
• Temporary or agency labour
• Electronics manufacturing
• Overseas supply chains
• Informal recycling and material recovery
• Complex subcontracting arrangements

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Ecoaera may not have full visibility over every stage of the original electronics manufacturing supply chain. We will focus on the suppliers, contractors and downstream partners that we directly select and control.

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7. Reporting concerns

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Anyone who suspects modern slavery or human trafficking connected with Ecoaera should report it promptly.

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Concerns can be reported to:

Name: Dan Guest
Position: Director

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Reports should include as much information as can be provided safely, including what happened, who was involved and when and where it occurred. No one should put themselves or another person at risk while gathering information. Where someone appears to be in immediate danger, the police should be contacted by calling 999.

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8. Responding to concerns

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Ecoaera will treat genuine concerns seriously and sensitively.

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We may:

• Investigate the concern
• Request further information from a supplier
• Require corrective action
• Suspend or end a business relationship
• Report suspected criminal activity to the appropriate authority
• Seek professional or legal advice

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Anyone raising a genuine concern in good faith will not be treated unfavourably for doing so.

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9. Breaches of this policy

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Breaches of this policy by employees or workers may result in disciplinary action. Breaches by suppliers, contractors or business partners may result in corrective action, suspension or termination of the relationship. Serious or deliberate involvement in modern slavery will not be tolerated.

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10. Responsibility and review

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The Director of Ecoaera Limited is responsible for overseeing this policy and responding to concerns.

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This policy will be reviewed at least annually and earlier if:

• Ecoaera’s operations or supply chain changes significantly
• A serious concern is identified
• Legal requirements change
• Ecoaera becomes legally required to publish a statutory statement

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11. Approval

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This Modern Slavery and Human Trafficking Policy has been approved by the Director of Ecoaera Limited.

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Signed on behalf of Ecoaera Limited:

Name: Dan Guest
Position: Director

Date: 3rd August 2026

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12. Contact details

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Company: Ecoaera Limited
Registered company number: 17060234
Registered office: 4c Lower Street, Tettenhall, Wolverhampton, West Midlands, WV6 9AF
Website: www.ecoaera.co.uk
Email: contact@ecoaera.co.uk
Telephone: 01902 96 25 96