Modern Slavery Statement 2025-26

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This statement has been produced in accordance with Section 54 of the Modern Slavery Act 2015 (‘the Act’). It constitutes our Modern Slavery Transparency Statement setting out the steps that Trident Maintenance Services Ltd (‘Trident’) has taken to ensure that slavery and human trafficking is not taking place in any part of our business or in our supply chains. This statement is in respect of Trident’s financial year ended 28 February 2026 and was approved by the Board of Directors on 27 August 2026.

Our Business

Trident provides quality painting and decorating and property maintenance solutions across the UK, in both the public and private sectors. We employ 160+ people and operate from several regional ‘hubs’ – including in Bellshill, Warrington, Cramlington, Bristol, Southampton, and Romford. We have gone from strength to strength in the past eight years with a £1.3m turnover in 2018/19, growing to £37.8m in 2025/26.

Recognising the harmful impact that modern slavery has on individuals and on society, we are committed to preventing illegal practices of modern slavery and human trafficking from occurring within our business and our supply chain. We acknowledge our responsibility under the Act and take a zero-tolerance approach to modern slavery in all its forms – and all forms of unethical business behaviour.

Modern slavery is one of the focus areas that makes up our Environmental, Social and Governance (ESG) framework at Trident – our internal and external stakeholders expect us to manage this risk and protect the rights and welfare of workers within our own business and our supply chains. The health and wellbeing of our people, partners and the public is Trident’s overriding priority.

To this end, we will:

  • Act responsibly, ethically, and with integrity in all our business dealings and relationships.
  • Implement and enforce effective systems and controls to mitigate modern slavery risk.
  • Develop sustainable relationships based on trust and cooperation.

Supply chain overview

We depend on our suppliers to deliver high-quality solutions to our business and ultimately to our clients, and we cultivate positive relationships with them that build trust and establish strong standards of business ethics and conduct. We have an Approved List of 200+ suppliers with whom we work to secure the materials, services and solutions we need to successfully manage our business and deliver our projects.

The majority of our spend is with reputable paint manufacturers and merchants based in the UK (although many also operate and manufacture globally):

  • Crown Paints: Products are primarily manufactured and produced within the UK at their main facilities in Darwen, Lancashire, and Hull.
  • AkzoNobel (Dulux): Most products are manufactured and produced within the UK at plants in Northumberland and Suffolk.
  • PPG (Johnstone’s and Leyland): Products are primarily manufactured and produced within the UK at their Batley facility in West Yorkshire.

We work with a wide range of specialist subcontractors to support us in the delivery of our projects where the requirements extend beyond our directly delivered workstreams of painting and decorating and associated building repairs, including scaffolders, roofers, electricians, plumbing and heating engineers, window and door fitters, floor layers, and asbestos specialists.

We work with a high percentage of small- to medium-sized businesses, selected locally to the areas in which we are working, accounting for much of our procurement spend.

Whilst our relationships with our material suppliers and subcontractor partners are critical to our overall success, we also recognise that the purchase of materials and the engagement of external contractors carry the highest risk in our supply chain in relation to modern slavery and human trafficking and we acknowledge the importance of maintaining vigilance.

However, mitigating the risk in our supply chain:

  • We do not have long subcontracting tiers.
  • We do not routinely use labour supply agencies.
  • Suppliers are subject to a due diligence, pre-qualification process.
  • We source materials predominantly from within the UK.
  • Our key material suppliers that meet the definition of a relevant commercial organisation under Section 54 of the Act are required to publish their own Modern Slavery Statements.

Policy

A written Slavery & Human Trafficking Policy is in place, approved and signed by Trident’s Managing Director, detailing our commitments to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our own organisation through our direct operations. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, volunteers, subcontractors, external consultants, third-party representatives, and business partners.

Our commitment is to:

  • Assess modern slavery and human trafficking risks in our business and supply chain.
  • Comply with all relevant employment and human rights laws in the UK.
  • Conduct due diligence and pre-qualification checks on our suppliers.
  • Define clear supplier expectations and assess supplier compliance according to identified risk.
  • Provide training to employees.
  • Make guidance available to suppliers and customers to support their due diligence programmes.
  • Provide a whistleblowing service for employees and external stakeholders to report any concerns.
  • Monitor and review our performance to continually improve.

Code of Conduct

Our Code of Conduct sets out the behaviours we expect of our people when dealing with each other, our clients, supply chain, communities and other stakeholders, ensuring all act in line with our core values, relevant laws and regulations, industry standards, and stakeholder expectations.

The Code is supported by our Ethical Business Practice, People and Inclusion Policies, which outline our alignment to the ETI Base Code, the UN Guiding Principles on Business and Human Rights, and ILO conventions, including:

  • Inclusion and diversity
  • Non-discrimination and non-harassment
  • Prevention of human trafficking
  • Elimination of forced child labour
  • Workplace health and safety
  • Fair working practices
  • Freedom of association
  • Supply chain performance

Our Supplier Code of Conduct sets out the obligations and responsibilities that we expect of our suppliers, including their alignment to Trident standards. The Code requires all suppliers to align to and uphold human rights principles, and to provide fair and equitable working conditions for employees. Suppliers are obliged to take action to identify and prevent modern slavery within their own operations and supply chain.

Our Code of Conduct and all policies are reviewed by our Board of Directors annually.

Whistleblowing

We foster a culture of openness and accountability and encourage all our workers, customers, business partners and other external stakeholders to raise any concerns related to the direct activities, or the supply chains, of Trident. This includes any circumstances that may give rise to risk of slavery or human trafficking.

The aim of our Whistleblowing Policy is to ensure that our workers and others are confident that they can raise any matters of genuine concern without fear of reprisals, in the knowledge that they will be taken seriously and that the matters will be investigated appropriately and recorded as confidential.

Risk assessment and due diligence

We seek to proactively manage any incidents of modern slavery and human trafficking through our risk management process which is operated and reviewed annually taking into account country-level, product-level and supplier-type risks. Our process is to:

  1. Map the supply chain: Identify Tier 1 suppliers, subcontractors, geographical sourcing regions, and specific labour profiles.
  2. Screen for inherent risks: Evaluate the sector, product type, labour intensity, and UK governance vulnerabilities.
  3. Evaluate: Use the government’s Modern Slavery Assessment Tool (MSAT) to score governance, recruitment policies, and due diligence.
  4. Conduct deeper due diligence: Supplier Assessment Questionnaire, supplier audits, and compliance reviews of high-risk areas.
  5. Document and monitor: Document findings in a risk matrix, create improvement plans, and track year-on-year effectiveness.

By developing and maintaining relationships with our supply chain partners that are built on trust, accountability and transparency, we are better able to determine potential risks and take proactive measures towards mitigating them.

Supplier verification

We undertake rigorous checks of our supply chain through effective supplier screening, onboarding and regular monitoring. Our robust due diligence and risk assessment process include pre-qualification criteria, contractual obligations and minimum trading standards. We expect our supply chain partners to implement ethical business practices, and we select them responsibly on this basis.

To become registered on our Approved List, suppliers are required to complete a Supplier Assessment Questionnaire, which includes questions on modern slavery and human trafficking, ethical business practices, and rights to work.

We prefer supply chain partners to be accredited to Constructionline Gold and/or SafeContractor which contain specific questions regarding modern slavery, human trafficking and ethical business practices, with annual renewals. These accreditations provide additional independent assurance regarding suppliers’ systems and processes in relation to modern slavery, human trafficking, and ethical business practices.

Compliance with the above, our policies, and Supplier Code of Conduct is a prerequisite for any business engagement.

Once projects commence, we monitor on-going compliance through our internal audit programme, including monitoring any concerns raised through our whistleblowing process.

Material procurement

To mitigate risks associated with material procurement, we have developed a Procurement Policy to establish permitted purchase rules and to reduce supply chain risk. We prioritise established suppliers who maintain robust ethical and sustainable sourcing policies.

Employment checks

We undertake strict employment checks as part of our recruitment process including obtaining photographic ID and proof of right to work in the UK (full passport or birth certificate) and ensuring employees are paid into their own personal bank account.

Training

All employees are required to undertake modern slavery e-learning as part of our mandatory training procedure with refresher training undertaken every three years, or every one year for those in higher-risk roles. The training concludes with a test to assess employees’ understanding of how to identify the risks and signs of modern slavery, which they are required to pass.

Site workers receive further training and briefings through site inductions on-site Toolbox Talks.

We also promote modern slavery training to our employees, suppliers and customers through the Supply Chain Sustainability School and collaborate with industry organisations, peers and platforms to inform best practice.

Performance

To monitor our performance, we:

  • Perform regular supplier audits and compliance reviews of high-risk supply chains.
  • Monitor whistleblowing reports and grievances.
  • Review our policies, risk assessments, and operating procedures annually, and secure Board approval for continuous improvements.

To the date of this statement, Trident has had no identified instances of modern slavery.

Opportunities

  • Develop a formal suite of KPIs to monitor our performance through metrics, e.g. the percentage of the workforce who have completed modern slavery training, the number of our suppliers registered with the Supply Chain Sustainability School, and the number of whistleblowing reports received.
  • Use digital technologies to reduce risk, strengthen compliance and safeguard communities. For example, to track operative skills and qualifications prior to site deployment to ensure only certified professionals are sent to live jobs.
  • We have strong oversight of our direct (Tier 1) suppliers but acknowledge that our visibility of the lower tiers of our supply chain remains a key area for development.

Kenny Robson
Managing Director
For and on behalf of Trident Maintenance Services Ltd
27 August 2026

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