Modern Slavery & Human Trafficking


This statement is made by RO Trading Limited, registered office: Graham House, 7 Wyllyotts Place, Potters Bar, Hertfordshire EN6 2JD. This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken during the year ending 31 March 2019, and action planned to prevent modern slavery and human trafficking in the businesses and its supply chain.


RO Trading is a family run company that can trace its roots back over 86 years; it only operates in the UK.

Based upon the founding principle that the company is ‘In business to do business’ this straightforward direct approach has seen it thrive over the years through careful engagement in a diverse range of interests, which continues to this day. 

Presently the company works in the property sector through asset management, refurbishment and development, procurement of land, new build and lodge site developments. As part of its social responsibility programme, it also provides substantial support to local community charitable projects and causes. The company places an important emphasis on integrity throughout its businesses and has a rigorous approach to health and safety and ethical business practices. This statement forms part of our commitment to ensure that there is no modern slavery or human trafficking in our supply chain or in any part of our business.

Supply chain

Due to the nature of our operations, we engage with a large number of suppliers, manufacturers, consultants, contractors and sub-contractors. Our supply chain includes the engagement of contractor organisations to carry out works and services on our development sites and the sourcing of materials and manufactured products.

We have developed long-standing relationships with our suppliers, manufacturers, consultants, contractors and sub-contractors and make clear our expectations of business behaviour and our high level of standards expected.

We appoint principal contractors and expect that all materials used in our developments and refurbishments are procured from sources that have not been identified as being at risk from modern slavery and human trafficking. We regularly monitor the people we work with by utilising systems we have place for media news and financial alerts and checks.

Policies and values

We have a number of policies and values which together address our commitment to eliminating the risk of modern slavery and human trafficking taking place within our businesses and in our supply chain, as well as ensuing we act ethically and with integrity in all our business relationships. This includes our policies and values on:

  • Anti-bribery & Corruption
  • Whistleblowing
  • Equal Opportunities, covering:
    - Fixed-term Employees & Agency Workers
    - Recruitment & Selection
  • Employee Promise
  • Health & Safety


Our recruitment processes are reviewed regularly. We have procedures in place for the vetting of new employees and undertake references and checks to confirm their identities. Employees are paid directly into an appropriate, personal bank account. We have policies and procedures in place to ensure compliance with UK employment and human rights laws and all staff are remunerated fairly and above the UK’s national living wage.  

We encourage employees to report in good faith any issues or concerns they may have regarding unethical business practices.

Targets for the current financial year

 1. To continue to monitor and educate our staff and supply chain

All staff will be provided with online compulsory training which delivers information on the definition of modern slavery and human trafficking, practical examples of how slavery and/or human trafficking can take place within our businesses and our supply chains. Reinforcement of how to report any concerns of modern slavery and/or human trafficking will be provided to all of our staff and supply chain on an annual basis.  

We will encourage our staff and anyone in our supply chain to report in good faith any issues or concerns they may have regarding unethical business practices.

2. To undertake due diligence to ensure compliance

As part of our ongoing commitment to compliance, we are a member of Constructionline and look to progress our membership to Gold level shortly. Gold level membership allows for the monitoring of subscribing supplier members, thereby minimising the risk of modern slavery and human trafficking in our supply chain.  

Constructionline will provide questions that supplier members need to complete in order to be visible on Constructionline and comply with legislation, with questions that require full disclosure of their employees’ eligibility to work in the UK including details of their action taken to eradicate slavery in their workforce, where appropriate.

3. To encourage all of our supply chain to confirm that they are taking positive steps to eliminate modern slavery and human trafficking

For non-construction businesses that we work with or those not covered by Gold membership with Constructionline we will look to implement a self-assessment on an annual basis or as and when deemed necessary.

4. To continue to develop our approach to tackling the issue of modern slavery

If we identify anyone within our supply chain who are at a higher risk of unfair working practices, modern slavery or human trafficking, we will undertake a more in-depth assessment and require those suppliers, manufacturers, consultants, contractors and sub-contractors to complete a detailed self-assessment questionnaire.

We will continue to monitor the supply chain to assess the risk of slavery and human trafficking being present and develop measures to further mitigate against any such risk. 

Approved by the board of directors on 19 December 2018

Signed on its behalf by

Richard Rowlandson


RO Trading Limited