Modern Slavery & Human Rights Policy

1. Purpose

Top Cleans is committed to operating ethically, transparently, and with respect for fundamental human rights. We have zero tolerance for modern slavery in all forms, including forced labour, servitude, human trafficking, debt bondage, and exploitative child labour. This policy outlines our commitment to preventing modern slavery within our business, workforce, and supply chains.

2. Scope

This policy applies to all people working for or on behalf of Top Cleans, including:

• Employees

• Contractors and subcontractors

• Franchise partners and their workers

• Suppliers, vendors, and business partners

3. Our Commitment

Top Cleans will:

• Act ethically, with integrity, and in compliance with applicable laws and human rights standards.

• Ensure that modern slavery has no place in our own operations or those of our suppliers.

• Promote transparency, fairness, and dignity for all people involved in our business activities.

• Take proactive steps to identify and address modern slavery risks in our operations and supply chains.

4. What Modern Slavery Means

Modern slavery refers to situations where a person’s freedom is exploited for another person’s benefit. It includes, but is not limited to:

• Slavery: Exercising ownership or control over another person

• Servitude: Being forced to work through coercion

• Forced labour: Work performed under threat or penalty without voluntary consent

• Human trafficking: Recruitment, transportation, or harbouring of people for exploitation

• Exploitation of children: Employing children in harmful, exploitative, or dangerous work

5. Our Principles & Actions

5.1 Ethical Employment

We respect workers’ rights and ensure all employees and contractors receive lawful pay and conditions.

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5.2 Supplier Expectations

We expect our suppliers and service partners to uphold ethical labour standards consistent with this policy. We aim to work with partners who share our commitment to human rights and ethical conduct.

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5.3 Due Diligence & Risk Management

We will:

• Assess risk areas where modern slavery could occur

• Conduct checks and monitoring of suppliers and contractors

• Take corrective action where risks are identified

5.4 Reporting & Feedback

Employees, workers, clients, or suppliers who have concerns about modern slavery can raise them promptly through our feedback channels. All reports will be taken seriously, investigated promptly, and handled confidentially.

5.5 Non-Retaliation

Individuals reporting concerns in good faith will not be subject to retaliation, discrimination, or disadvantage.

6. Responsibilities

All people working for or on behalf of Top Cleans must:

• Understand and comply with this policy

• Report any concerns about modern slavery or human rights risks

• Cooperate with investigations or due diligence processes

Our management team is responsible for implementing and enforcing this policy across all business areas.

7. Continuous Improvement

We are committed to regularly reviewing this policy, updating our processes, and improving how we identify and mitigate risks of modern slavery. This policy will be reviewed at least annually or whenever significant changes occur.

8. Contact

For questions, concerns, or to report a possible issue related to this policy, please contact:
Top Cleans

info@topcleans.co.nz