Modern Slavery Statement

Version 1.0 — 2026-04-27 · Financial year ending 31 March 2026 · Approved by the sole director on 27 April 2026.

This statement is published by Bayswater Transflow Engineering Ltd. ("Bayswater") for the financial year ending 31 March 2026. It is structured to align with section 54 of the Modern Slavery Act 2015 and addresses the six areas of disclosure suggested in section 54(5) of that Act.

Status of this statement. Bayswater does not currently meet the £36 million annual turnover threshold in section 54(2) of the Modern Slavery Act 2015 and is therefore not under a statutory obligation to publish a slavery and human-trafficking statement. The company has elected to publish this statement voluntarily, aligned to the statutory framework, in recognition of the inherent modern-slavery and labour-exploitation risks present in cross-border construction- worker placement, and in line with the expectations of our enterprise clients.

1. Statement of intent and reporting period

Bayswater is committed to operating with integrity in all its relationships and to taking all reasonable and proportionate steps to ensure that modern slavery, servitude, forced or compulsory labour, and human trafficking (collectively, "modern slavery") do not occur in any part of our business or our supply chains. We adopt a zero-tolerance approach. This statement covers the financial year ending 31 March 2026 and replaces any previous statement; it will be reviewed and republished annually.

2. Organisation structure, business and supply chains

Bayswater is a private limited company incorporated in England and Wales (company number 16277213), registered office 128 City Road, London EC1V 2NX, United Kingdom. Bayswater operates as both an employment agency and an employment business within the meaning of the Employment Agencies Act 1973 and is subject to oversight by the Employment Agency Standards Inspectorate.

Bayswater's principal activity is the cross-border mobilisation of construction-sector workers — masons, pipefitters, electricians, scaffolders, civil-mason crews, and adjacent trades — to enterprise clients (main contractors, EPC contractors, and energy operators) across the European Union and adjacent jurisdictions. Workers are principally sourced from India, the Gulf region, and South-East Asia and deployed under regulated routes that include posted-worker arrangements, intra-EU mobility, and country-specific work-visa pathways.

Bayswater's supply chain is concentrated in two tiers: (i) source-country recruitment partners ("Recruitment Agents") who identify and present candidates within their local markets; and (ii) destination-country professional services suppliers (legal counsel, immigration counsel, payroll providers, posted-worker compliance providers, accommodation providers, training and certification bodies). Bayswater itself does not own labour-supply contractors and does not subcontract its core screening or deployment work to third parties.

3. Policies in relation to slavery and human trafficking

The following policies are maintained internally and applied to all Bayswater operations and supply-chain relationships:

  • Anti-Slavery and Human Trafficking Policy — sets the zero-tolerance posture, defines reporting routes, and binds all directors, officers, employees, and agents.
  • Ethical Recruitment Policy — codifies the no-fee principle, prohibits document retention, prohibits deceptive recruitment practices, and adopts the principles of the International Labour Organization's General Principles and Operational Guidelines for Fair Recruitment.
  • Recruitment-Agent Code of Conduct — minimum standards required of every source-country Recruitment Agent, including no candidate fees, no document retention, audit-rights, worker-grievance escalation, and termination on breach.
  • Right to Work and Identity Document Handling Policy — governs how identity documents are inspected, recorded, and returned; documents are not retained beyond the verification step.
  • Whistleblowing Policy — provides confidential reporting channels for staff, candidates, and partners.
  • Equal Opportunities and Anti-Harassment Policy — addresses dignity, equal treatment, and freedom from discrimination across recruitment, deployment, and supervision.
  • Anti-Bribery and Corruption Policy — addresses corruption-related modern-slavery risk in source-country recruitment markets, in compliance with the Bribery Act 2010.

4. Due diligence processes

Bayswater conducts due diligence at three layers:

  • Recruitment-Agent onboarding. Each prospective Recruitment Agent is screened against documented criteria covering ownership, regulatory standing in the home jurisdiction, prior conduct, and references. A signed Recruitment-Agent Code of Conduct is a precondition of engagement. Agents are re-assessed annually.
  • Candidate intake. Every candidate is interviewed directly by a Bayswater representative, separately from the Recruitment Agent, in their preferred language. The candidate is asked specifically about any fees paid or promised, any retained documents, and any recruitment promises made to them. Each candidate signs a written attestation that no fee has been or will be charged by Bayswater for the work-finding service.
  • Destination-country supplier review. Professional-services suppliers in destination countries are subject to written engagement terms that require compliance with applicable employment, immigration, and posted-worker legislation, and that include co-operation rights for any modern-slavery or labour-exploitation investigation.

5. Risk assessment and management

Bayswater's modern-slavery risk register identifies the following inherent vectors specific to the cross-border construction-worker placement business model:

  • Sub-agent fee extraction in source markets. The most material residual risk is the possibility that a Recruitment Agent or unauthorised sub-agent charges a candidate a recruitment fee outside Bayswater's visibility — a known vector in international labour-supply markets. This is mitigated by direct candidate interviews, written no-fee attestations, post-deployment verification calls, and the contractual right to terminate any Recruitment Agent on first substantiated finding.
  • Document retention by intermediaries. Retention of passports or identity documents is a recognised indicator of forced labour. Bayswater requires that no third party retain candidate documents and verifies this both at intake and post-deployment.
  • Excessive working hours and accommodation conditions. Construction-site posting carries inherent risks of long hours and substandard accommodation. Mitigation is through written working-time and accommodation standards in the engagement terms with the hirer, and through post-deployment worker contact.
  • Wage substitution and unauthorised deductions. Mitigated by contractual transparency, payroll-provider segregation, and worker contact.
  • Restricted movement. Mitigated by ensuring workers retain freedom of movement, freedom to terminate engagement subject to notice, and access to independent grievance channels.

Risk is reviewed quarterly by the Compliance Officer and reported to the sole director on the same cadence. High-risk source-country corridors are subject to enhanced controls including additional candidate-interview steps and shorter audit cycles.

6. Recruitment-sector-specific safeguards

The following safeguards are specific to Bayswater's status as a regulated employment agency and employment business under the Employment Agencies Act 1973 and the Conduct of Employment Agencies and Employment Businesses Regulations 2003:

  • Candidate-charging prohibition. Bayswater never charges work-seekers any fee for the work-finding service, in compliance with section 6 of the Employment Agencies Act 1973 and Regulation 5 of the Conduct Regulations 2003. Each candidate signs a no-fee attestation at intake and is re-contacted post-deployment to confirm no fees were paid to any third party including source-country Recruitment Agents.
  • Independence of Recruitment Agents. Bayswater does not require any candidate to use a specific Recruitment Agent and does not condition engagement on the use of any third-party service.
  • Document handling. Bayswater inspects identity documents only as required for right-to-work or visa purposes; no Bayswater agent retains worker passports or identity documents after the verification step. Document-handling logs are maintained.
  • Multilingual grievance channel. A confidential grievance line is accessible to deployed workers in their working language, independent of client-facing staff and independent of source-country Recruitment Agents. Workers are also signposted to the Modern Slavery & Exploitation Helpline (08000 121 700) and to their destination-country labour inspectorate.
  • Post-deployment verification. Each deployed worker is contacted directly at defined intervals (typically days 7, 30, and 90, and at any contract renewal) to confirm working conditions, payment of wages, accommodation standards, and the absence of retained documents or unauthorised deductions.
  • Right-to-work and posted-worker compliance. Right-to-work checks are conducted in line with the Home Office Code of Practice; A1 / posted-worker filings for EU deployments are completed in line with the Posted Workers Directive (96/71/EC, as amended by 2018/957/EU) and applicable national transpositions.

7. Effectiveness and key performance indicators

Bayswater measures the effectiveness of its modern-slavery controls against the following indicators, reviewed by the sole director annually:

  • Percentage of candidates re-contacted post-deployment to verify no fees paid and no documents retained.
  • Number of Recruitment-Agent audits conducted, by source country and by tier of risk.
  • Number of grievances raised through the multilingual channel; number resolved within target time; number escalated to law enforcement.
  • Percentage of suppliers (Recruitment Agents and destination-country professional-services suppliers) covered by a signed Code of Conduct or equivalent contractual modern-slavery clause.
  • Percentage of personnel with annual modern-slavery training completion.
  • Number of substantiated modern-slavery findings, with corrective-action outcomes.

For the financial year reported in this statement, Bayswater is in its first full operating year and the indicators above are being captured for the first time. Quantitative figures will be disclosed in the next annual statement once a full reporting cycle is available; this is itself a transparency commitment under section 54(5)(e) of the Modern Slavery Act 2015.

8. Training

All Bayswater personnel complete a modern-slavery awareness module during induction and refresh training annually. Personnel involved in candidate interviews, post-deployment verification, or Recruitment- Agent management complete enhanced training covering: indicators of forced labour, the Survey on Forced Labour indicators developed by the International Labour Organization, the UK National Referral Mechanism, referral routes to the Gangmasters and Labour Abuse Authority, and the Modern Slavery & Exploitation Helpline. Recruitment Agents are required to confirm equivalent staff training in their local markets.

9. Looking ahead

During the next reporting period Bayswater intends to:

  • complete the first full annual cycle of post-deployment verification calls and disclose the resulting indicators in the next statement;
  • conduct in-country audits of all source-country Recruitment Agents at least once during the year;
  • publish a refreshed Recruitment-Agent Code of Conduct incorporating any lessons learned from the first audit cycle;
  • extend modern-slavery awareness training to nominated points-of-contact at each enterprise client where the contractual relationship allows; and
  • review the registration of this statement on the UK Government Modern Slavery Statement Registry once the first full reporting cycle is complete.

10. Reporting concerns

Any concern regarding modern slavery, labour exploitation, or any matter covered by this statement may be reported confidentially to compliance@bayswatertransflow.com or by post to 128 City Road, London EC1V 2NX, United Kingdom. Reports may be submitted anonymously and will be investigated. Concerns may also be raised independently with:

  • Modern Slavery & Exploitation Helpline: 08000 121 700 (UK, 24-hour, multilingual; modernslaveryhelpline.org)
  • Gangmasters and Labour Abuse Authority (GLAA): gla.gov.uk
  • UK Police (in case of immediate risk to a person): 999
  • UK National Referral Mechanism for potential victims of modern slavery via a First Responder organisation.

Approval and signature

Bayswater Transflow Engineering Ltd. is a single-director private limited company incorporated in England and Wales. This statement was approved and adopted by the sole director, Tanishq Chauhan, on 27 April 2026, and is signed below.

Tanishq Chauhan
Sole Director
Bayswater Transflow Engineering Ltd.
27 April 2026