Anti-Slavery Policy

Three Shapes Management also Trading as SEP Engineers, SEP Geospatial, SEP Technical and SEP Subsurface commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

Hidden labour exploitation is exploitation of job applicants or workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.


This policy applies to all locations under our control.


Carl Housbey (Managing Director) has overall responsibility for this policy

Luke Nixon (Engineers Director), Oliver Brooks (Geospatial and Sub Surface Director) have specific responsibilities for ensuring that prospective SEP employees have knowledge of this policy.

Policy Commitments

We shall:

1. Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.

2. Accept that job finding fees are a business cost and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.

3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.

4. Ensure that labour sourcing, recruitment, and worker placement processes are under the control of trusted and competent staff members.

5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.

6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through (list formats e.g. in a variety of formats such as workplace posters, worker leaflets, induction, other training.)

7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.

8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities.

Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.


A copy of this policy is available upon request