At Foxway Circular UK Ltd, we uphold the highest ethical standards in all our business activities and across our supply chain. Our commitment to responsible and sustainable corporate governance ensures that our practices align with human rights and employment legislation wherever we do business.
In today’s global market, the significance of business ethics continues to grow. As a member of the Swedish headquartered Foxway group, we are committed to acting with integrity and preventing corruption in any form. We maintain a zero-tolerance policy for unethical conduct, expecting every Foxway employee and representative to prioritise the company’s interests above personal biases or affiliations. As ambassadors of Foxway, we strive to set a high standard for both society and the industry at large.
Based in Braintree, Essex, United Kingdom, Foxway Circular UK Ltd, we operate a state-of-the-art processing facility with a dedicated team of over 145 skilled employees. We collaborate with leading manufacturers, resellers, lessors and retailers to help their enterprise and public sector clients adopt a more circular approach. We manage their global reverse logistics needs for used IT equipment in a way that balances both cost efficiency and environmental responsibility.
We call it Circular Tech.
We offer a variety of recovery services for used devices like computers, tablets, mobile phones, servers, storage systems and networking equipment, ensuring a seamless transition for current users when it’s time to upgrade. Upon receiving these products, we securely delete all data before refurbishing and repairing or harvesting parts from them. Additionally, we provide buyout solutions for surplus stock.
Through our Remarketing Services, we give unsold, returned, or used devices a second life, offering them to new users around the world. These services deliver true circularity and value, benefiting both end users and our partners.
Our Advisory & Insights division, leveraging artificial intelligence and advanced analytics, provides customers with critical insights about their tech devices. These insights could be related to climate impact, cost analysis, or technical data, enabling our customers and partners to maximise the value of their technology investments.
Modern Slavery
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of above £36 million to prepare and publish an annual ‘Slavery and Human Trafficking Statement’. The Statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its supply chain.
Our Policy
Our policy is to comply with applicable modern slavery, human trafficking, employment and human rights legislation and to take reasonable steps to identify, assess and mitigate modern slavery risks within our business and supply chain.
We expect organisations with whom we do business to adopt and enforce policies and practices that comply with applicable legislation. In support of this commitment, we ensure:
- Our values, which are embedded throughout our business, set the parameters for how we expect our people to behave with colleagues, customers around the world.
- We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted.
- Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.
- We protect whistleblowers and provide appropriate channels for employees, contractors and business partners to raise concerns confidentially and without fear of retaliation.
Our Supply Chain
Our supply chain includes suppliers of goods and services, logistics providers, contractors, partner organisations, downstream processing and recycling partners, and other organisations that support the delivery of services to our customers.
We recognise that modern slavery risks can exist within complex and multi-tier supply chains, particularly where services involve logistics providers, temporary or agency labour, contractors, downstream recycling and processing partners, and international supply chains. Foxway adopts a risk-based approach to identifying, assessing and mitigating these risks through supplier due diligence, contractual requirements, ongoing monitoring and employee awareness.
We apply a risk-based approach to supplier onboarding and management. This may include supplier assessment, contractual commitments, review of modern slavery controls, ongoing monitoring and escalation of concerns where identified.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and we have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Provide information and training to employees.
Our commitment
As part of our commitment to preventing modern slavery and human trafficking, we regularly review our policies, procedures and controls to assess their effectiveness and identify opportunities for continuous improvement.
We have zero tolerance for modern slavery and human trafficking and continually review and strengthen our internal controls, policies and compliance processes.
Our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Foxway Circular UK Ltd during the period 1 January 2025 to 31 December 2025 to prevent modern slavery and human trafficking in its business and supply chains.
Signed on behalf of the Foxway Circular UK Ltd Board of Directors
Chris Farrell, General Manager
6th February 2026
