Employees and contractors
Individuals undertaking operational, administrative, technical and business-support responsibilities.
Voluntary Corporate Statement
Modern Slavery Statement.
Black Fleet London is committed to conducting business responsibly and does not tolerate slavery, servitude, forced labour, compulsory labour, human trafficking or exploitation within its operations or supply chain.
This is a voluntary corporate statement reflecting Black Fleet London’s ethical-business commitments and supplier expectations. It does not represent that the company is currently subject to the statutory reporting threshold under section 54 of the Modern Slavery Act 2015.
Our Commitment
Respect for human dignity throughout our operations and supply chain.
Black Fleet London recognises that modern slavery can arise through coercion, deception, abuse of vulnerability, withholding of documents, unlawful deductions, debt bondage, threats or other forms of exploitation.
We seek to work with employees, contractors, licensed private hire operators and suppliers who share our commitment to lawful, fair and responsible business conduct.
Zero-tolerance principles
- No forced, bonded, trafficked or compulsory labour
- No retention of identity documents as a means of control
- No recruitment fees creating exploitative worker debt
- No threats, coercion, intimidation or restriction of movement
- No unlawful withholding of earnings or contractual payments
- No retaliation against individuals raising genuine concerns
Our Business and Supply Chain
A managed ground transportation operation supported by external services.
Black Fleet London Ltd provides professionally managed chauffeur and passenger transportation services in London, at airports, across the United Kingdom and for longer-distance travel requirements.
Licensed operators
A well-connected network of licensed private hire operators supporting transport capacity, vehicle classes and geographical coverage.
Chauffeur services
Professionally licensed chauffeurs carrying out passenger journeys under the relevant operating arrangements.
Vehicle supply
Vehicle owners, rental providers, maintenance services and other transport-related suppliers.
Technology providers
Hosting, booking, communications, payment, website and operational technology services.
Professional services
Accounting, legal, insurance, compliance and other specialist support.
Goods and equipment
Office equipment, mobile devices, uniforms, vehicle accessories and other operational goods.
Business partners
Travel, hospitality, aviation, events and corporate organisations connected to service delivery.
Ethical Business Principles
Responsible commercial relationships built on lawful and fair treatment.
Black Fleet London’s approach is based on prevention, proportionate supplier checks, clear expectations, accessible reporting and appropriate action where concerns are identified.
Lawful work
Work must be voluntary and carried out under lawful arrangements.
Fair treatment
Individuals should be treated with dignity and without exploitation.
Transparent terms
Payment, responsibilities and relevant working conditions should be clear.
Speak-up protection
Genuine concerns should be raised without fear of retaliation.
Potential Risk Areas
Attention directed towards relationships where vulnerability may be greater.
Black Fleet London considers risk according to the nature of the service, employment or contracting model, geographical factors, payment arrangements, use of intermediaries and the visibility available within the supply chain.
Multi-tier subcontracting
Risk may increase where the party delivering the service is not clearly connected to the organisation receiving payment.
Unclear employment status
Individuals may be vulnerable where contractual status, payment terms or responsibility for work is unclear.
Recruitment intermediaries
Recruitment fees, document retention or misleading promises may create conditions for exploitation.
Financial pressure
Excessive deductions, withheld payments or dependency on one intermediary may increase vulnerability.
Limited supplier visibility
Risk may be harder to assess where ownership, licensing, workforce or subcontracting information is unavailable.
Vulnerable workers
Migrant, temporary, low-paid or isolated workers may face greater difficulty reporting exploitation.
Supplier Due Diligence
Proportionate checks before and during important supplier relationships.
Due diligence should reflect the size, nature and risk of the supplier or operating relationship rather than applying identical requirements in every circumstance.
01
Identify
Confirm the organisation or individual providing the service.
02
Assess
Consider labour, subcontracting, geographical and commercial risk.
03
Verify
Review proportionate business, licensing and compliance information.
04
Communicate
Issue ethical, operational and reporting expectations.
05
Monitor
Review concerns, changes and relevant performance information.
Supplier Expectations
Suppliers expected to operate lawfully and treat people fairly.
Suppliers and licensed private hire operators supporting Black Fleet London should take reasonable steps to prevent modern slavery within their own operations and relevant supply chains.
They should cooperate with proportionate enquiries and promptly report credible concerns connected to services delivered for Black Fleet London.
Core expectations
- Comply with applicable employment and anti-slavery laws
- Do not use forced, trafficked or compulsory labour
- Do not retain passports or identity documents as leverage
- Maintain transparent payment and contracting arrangements
- Avoid unauthorised or hidden subcontracting
- Provide a route for workers to raise concerns
- Report suspected exploitation without unnecessary delay
Recruitment and Engagement
Individuals engaged through transparent arrangements
Black Fleet London seeks to understand the identity, status and role of individuals and organisations providing services to the business.
Individuals should not be required to pay exploitative recruitment fees, surrender identity documents or enter misleading or coercive working arrangements.
Payment and Commercial Conduct
Financial arrangements should not create exploitation
Payment terms, deductions and commercial responsibilities should be communicated clearly and administered according to the relevant agreement.
Concerns involving unexplained deductions, withheld earnings, coercive debt or financial control should be escalated.
Raising a Concern
Genuine concerns should be reported safely and promptly.
Employees, contractors, chauffeurs, operators, suppliers and other stakeholders should report credible concerns involving forced labour, trafficking, coercion, document retention, unlawful payment practices or other forms of exploitation.
Individuals should not place themselves in danger or attempt to conduct their own investigation.
Reporting principles
- Report concerns through Black Fleet London’s appropriate contact route
- Record facts rather than assumptions where possible
- Preserve relevant information without confronting suspected offenders
- Contact emergency services where there is immediate danger
- Maintain confidentiality as far as reasonably possible
- Do not retaliate against anyone raising a genuine concern
Immediate danger
Where a person appears to be in immediate danger or a serious crime may be occurring, the police or appropriate emergency service should be contacted. Routine internal reporting should not delay urgent assistance.
Responding to Concerns
Concerns assessed carefully and escalated according to risk.
Protect
Consider immediate safety, confidentiality and the risk of retaliation.
Assess
Review the available information and determine the seriousness and credibility of the concern.
Escalate
Refer matters to leadership, clients, advisers or public authorities where appropriate.
Remediate
Consider corrective action, supplier restrictions, suspension or termination according to the circumstances.
Awareness and Communication
Relevant people should understand warning signs and reporting routes.
Awareness may be communicated through policies, supplier standards, onboarding, operational guidance and targeted briefings.
The level of guidance should reflect the individual’s role and the nature of their contact with workers, suppliers and operating partners.
Awareness topics may include
- Indicators of coercion and restricted freedom
- Retention of identity or immigration documents
- Recruitment debt and unlawful deductions
- Fearful, controlled or unexplained behaviour
- Hidden subcontracting and unclear employment arrangements
- Safe reporting and non-retaliation expectations
Roles and Responsibilities
Responsibility shared across leadership, operations and suppliers.
01
Director
Approves the statement, oversees significant risks and determines material supplier or corrective action.
02
Operations team
Applies supplier checks, communicates expectations and escalates concerns identified through operational activity.
03
Operators and suppliers
Maintain lawful working practices, cooperate with proportionate enquiries and report credible exploitation concerns.
04
All workers and contractors
Follow applicable ethical standards and raise genuine concerns without concealing suspected exploitation.
Monitoring Effectiveness
Progress reviewed through practical indicators
Black Fleet London may review supplier onboarding completion, compliance information, concerns raised, corrective actions and the communication of ethical-business expectations.
Measures should remain proportionate and should not create unsupported claims that the entire supply chain is free from all risk.
Review and Improvement
The statement developed as the business grows
This statement should be reviewed at least annually and following a significant concern, supplier change, operational expansion or material legal development.
Future improvements may include enhanced supplier declarations, risk-based reviews, targeted awareness and stronger contractual controls.
Proportionate transparency
Black Fleet London publishes this statement voluntarily as evidence of its ethical-business commitments. Publication does not represent that the company has audited every person or organisation within every supplier’s extended supply chain.
Approval
Leadership approval and accountability.
This voluntary statement has been approved on behalf of Black Fleet London Ltd and reflects the company’s current approach to modern slavery and human-trafficking risk.
The statement will be reviewed as the company’s operations, supplier network and governance arrangements develop.
Approved by
Black Fleet London Ltd
Approved by the Director on behalf of the company.
Constantin Alin Rata Founder and DirectorBlack Fleet London Ltd
Related Governance
Ethical conduct supported by connected policies.
Supplier Code of Conduct
Ethical, labour, compliance and reporting expectations for suppliers and operators.
Whistleblowing Policy
Protected routes for raising serious concerns about wrongdoing or unsafe conduct.
Anti-Bribery and Corruption Policy
Transparent commercial conduct and controls against improper influence.
Ethical Business and Due Diligence
Need further modern-slavery or supplier information?
Corporate clients and prospective partners may contact Black Fleet London regarding ethical-business requirements, supplier onboarding, procurement enquiries or proportionate supporting evidence.