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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Modern Slavery Policy

1. Purpose

The purpose of this Modern Slavery Policy is to set out the commitment of {{org_field_name}} to prevent, identify and respond to modern slavery, human trafficking, servitude, forced or compulsory labour, and related labour exploitation within our business, recruitment activities, supply chains and labour supply arrangements.

As a temporary staffing agency / employment business operating in England, {{org_field_name}} recognises that recruitment and temporary labour supply can present particular risks of worker exploitation. We are committed to acting lawfully, ethically and transparently, and to maintaining effective systems and controls designed to reduce the risk of modern slavery in our operations and in the organisations with which we work.

Modern slavery is a violation of fundamental rights and a criminal offence under the Modern Slavery Act 2015. This policy is intended to ensure that modern slavery has no place in our organisation, in our recruitment and supply practices, or in the third parties with whom we do business.

2. Scope

This policy applies to:

• All directors, managers, employees, consultants, and workers engaged directly by {{org_field_name}}, including zero-hours workers and bank staff.
• All applicants, candidates and agency workers engaged by or through {{org_field_name}} and supplied to external clients.
• All third-party suppliers, umbrella companies, intermediaries, payroll providers, subcontractors and service providers with whom {{org_field_name}} has a commercial relationship.

This policy applies to all stages of the recruitment and supply chain process, including advertising, candidate sourcing, registration, pre-engagement checks, right to work checks, onboarding, contractual documentation, assignment management, payroll arrangements, worker welfare, supplier due diligence, and the reporting and escalation of concerns.

This policy must be adhered to by all employees and workers and applies both within the business and when working on assignments at client locations.

3. Related Policies

• Recruitment Policy
• Whistleblowing Policy
• Safeguarding Adults and Children Policy
• Equality, Diversity and Inclusion Policy
• Complaints Policy
• Grievance and Disciplinary Policy
• Code of Conduct
• Health and Safety Policy

4. Policy Statement

{{org_field_name}} strictly prohibits modern slavery, human trafficking, forced or compulsory labour, servitude, and all forms of labour exploitation.

We are committed to acting ethically, lawfully and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to reduce the risk of modern slavery taking place anywhere in our business, recruitment activities, labour supply arrangements or supply chains.

{{org_field_name}} expects the same high standards from all persons and organisations with whom we work, including clients, suppliers, intermediaries, umbrella companies and service providers.

5. Legal Framework

This policy has been developed with regard to the following legislation and guidance, as amended from time to time:

• Modern Slavery Act 2015
• Employment Agencies Act 1973
• The Conduct of Employment Agencies and Employment Businesses Regulations 2003
• Agency Workers Regulations 2010
• Employment Rights Act 1996
• Working Time Regulations 1998
• National Minimum Wage Act 1998 and the National Minimum Wage Regulations 2015
• Equality Act 2010
• Immigration, Asylum and Nationality Act 2006
• Safeguarding Vulnerable Groups Act 2006
• Police Act 1997
• Rehabilitation of Offenders Act 1974 and the Rehabilitation of Offenders Act 1974 (Exceptions) Order 1975, where applicable
• UK GDPR and the Data Protection Act 2018
• Health and Safety at Work etc. Act 1974

Where {{org_field_name}} supplies staff into healthcare or care settings but does not itself carry on a regulated activity, Care Quality Commission registration requirements do not apply unless the business model changes so that {{org_field_name}} itself carries on a regulated activity in England.

6. Responsibilities

Directors and Senior Management

The directors of {{org_field_name}} are responsible for ensuring that this policy is implemented effectively. This includes:

• Conducting periodic modern slavery risk assessments across the business, recruitment activities, labour supply arrangements and supply chains.
• Appointing a named Director or Compliance Lead with responsibility for modern slavery compliance and escalation.
• Overseeing the development and delivery of appropriate training to relevant staff.
• Allocating sufficient resources to maintain compliance with legal and regulatory obligations.
• Ensuring recruitment and supply practices are transparent, lawful and fair.
• Ensuring appropriate contractual protections are included in arrangements with third parties, where relevant.
• Reviewing due diligence arrangements for clients, suppliers, intermediaries and umbrella companies.
• Approving an annual Modern Slavery Statement where legally required, and considering voluntary publication where appropriate.

Managers

Managers must:

• Ensure staff understand and comply with this policy.
• Monitor recruitment activity and worker welfare for signs of modern slavery, labour exploitation or coercion.
• Ensure recruitment is carried out transparently and in accordance with applicable law.
• Ensure that no prohibited recruitment fees are charged to work-seekers.
• Report any concerns regarding modern slavery immediately to the Director or Compliance Lead.
• Cooperate with investigations and ensure concerns are escalated without delay.

All Staff

All staff and workers:

• Must not engage in, facilitate or ignore modern slavery practices.
• Must immediately report any suspicion of modern slavery, trafficking or labour exploitation.
• Must comply with the Whistleblowing Policy and raise concerns without fear of reprisal.
• Must cooperate with any internal investigation or external referral process where required.

7. Managing Risks

Recruitment, Right to Work and Pre-Engagement Checks

{{org_field_name}} will operate transparent and lawful recruitment processes designed to reduce the risk of modern slavery and labour exploitation.

Before a worker is supplied, we will carry out appropriate pre-engagement checks relevant to the role and assignment. These may include identity verification, right to work checks, employment history review, reference checks, qualification checks and, where the role is legally eligible, DBS checks.

Right to work checks will be carried out in accordance with the Immigration, Asylum and Nationality Act 2006 and current Home Office guidance.

Where required by the Conduct of Employment Agencies and Employment Businesses Regulations 2003, agency workers will be provided with a Key Information Document before agreeing terms with {{org_field_name}}.

No work-seeker will be charged prohibited recruitment fees or be required to use ancillary services as a condition of being offered work where this would breach applicable law.

Workers will be issued with clear written terms, explained in an accessible way, including pay arrangements, holiday entitlement, deductions, notice provisions, complaint routes and whom they should contact if they have concerns about exploitation or coercion.

Worker Rights and Pay

{{org_field_name}} will provide workers with clear information about pay, holiday entitlement, working time, rest breaks, deductions, grievance routes and any statutory rights that apply to their status and assignment.

We will take reasonable steps to ensure that agency workers receive rights required by the Agency Workers Regulations 2010 and that all workers are paid at least the applicable National Minimum Wage or National Living Wage.

Supply Chain, Client and Intermediary Due Diligence

{{org_field_name}} will take a risk-based approach to assessing modern slavery and labour exploitation risk in its business relationships, including in relation to clients, labour suppliers, intermediaries, umbrella companies, payroll providers and other material suppliers.

Due diligence may include, where proportionate:

• Verification of the organisation’s identity and trading status.
• Review of available information relevant to reputation, complaints or adverse findings.
• Assessment of recruitment, pay, deduction and worker welfare practices.
• Confirmation of compliance responsibilities in contracts.
• Confirmation that workers are not being charged prohibited fees or subjected to unlawful deductions, document retention or coercive accommodation or transport arrangements.
• Periodic review or enhanced checks where higher-risk factors are identified.

Any supplier or intermediary found to present a serious modern slavery risk, or to have engaged in unlawful or exploitative conduct, may be suspended, investigated or have their contract terminated, depending on the circumstances.

Training

All relevant staff, including directors, managers and those involved in recruitment, compliance, payroll and worker management, will receive modern slavery and labour exploitation awareness training at induction and periodically thereafter.

The training will cover:

• Identifying signs of modern slavery and labour exploitation
• Reporting concerns
• Coercion, debt bondage, document retention and third-party control
• The role of temporary staffing agencies in reducing exploitation risk
• Safeguarding and escalation routes
• Confidentiality and appropriate record-keeping

Worker Welfare Monitoring

{{org_field_name}} will undertake proportionate welfare monitoring of workers on assignment, particularly where risk factors are present.

Welfare checks may include direct contact with the worker, confirmation of pay arrangements, discussion of working and living conditions, and review of any concerns raised by the worker, client or third parties.

We will pay particular attention to indicators such as:

• Workers appearing fearful, distressed or coached
• Workers being accompanied or controlled by third parties
• Retention of passports, identity documents or bank cards by third parties
• Bank details, addresses or contact details being controlled by someone else
• Unexplained deductions, withheld wages or wage diversion
• Dependence on a third party for transport or accommodation linked to the job
• Poor accommodation or living conditions

8. Record-Keeping and Data Protection

{{org_field_name}} will create and retain appropriate records to demonstrate compliance with this policy and with applicable legal obligations.

Records may include risk assessments, training records, due diligence records, checks carried out, concerns raised, investigations undertaken, actions taken and referrals made.

All personal data processed under this policy will be handled in accordance with UK GDPR, the Data Protection Act 2018 and internal data protection procedures.

Special category data and criminal offence data will only be processed where there is an appropriate lawful basis and condition for processing.

DBS certificate information and other sensitive records will be handled, stored, shared and retained in accordance with applicable law and guidance, and only for as long as necessary.

9. Agency-Specific Compliance Controls

As a temporary staffing agency / employment business, {{org_field_name}} recognises that compliance with agency worker legislation is an important part of preventing modern slavery and labour exploitation.

{{org_field_name}} will maintain systems and controls to support compliance with applicable agency legislation, including transparent terms of engagement, proper record-keeping, lawful charging practices, provision of Key Information Documents where required, and appropriate information-gathering about assignments and clients before supply.

We will also take reasonable steps to identify where recruitment or assignment structures could increase exploitation risk, including the use of umbrella companies, unusual deduction arrangements, tied accommodation or transport, high-volume low-pay assignments, or situations in which workers appear dependent on third parties.

10. Reporting Concerns

Internal Reporting

All concerns must be reported immediately to the Director or Compliance Lead of {{org_field_name}}.

If the concern involves that person, the matter must be reported under the Whistleblowing Policy to an alternative senior manager or director.

All concerns must be treated seriously, handled sensitively and escalated without delay where there is a safeguarding, criminal or serious labour exploitation risk.

External Reporting

In cases where immediate safety is at risk, staff must contact the police via 999.

Non-emergency criminal concerns may be reported to the police via 101.

For advice, the Modern Slavery Helpline (08000 121 700) is available 24/7.

Concerns relating to agency worker rights, labour exploitation or employment agency legislation may also be raised with the relevant labour market enforcement authority or reporting route in force at the time.

Where a potential victim is identified, {{org_field_name}} will consider whether referral or notification should be made through an appropriate first responder organisation and will handle the matter in a lawful, proportionate and victim-centred way.

If concerns relate to a child or vulnerable adult, safeguarding procedures must also be followed immediately, including referral to the relevant local authority or safeguarding authority where appropriate.

11. Confidentiality and Protection for Whistleblowers

All reports made under this policy will be handled as confidentially as possible, consistent with the need to investigate, safeguard individuals, comply with legal obligations and make external referrals where necessary.

Information will be shared only with those who need to know and in accordance with data protection law.

{{org_field_name}} will not tolerate retaliation, victimisation or detriment against any worker, employee or other person who raises a concern in good faith, assists with an investigation, or refuses to participate in conduct they reasonably believe may involve exploitation or modern slavery.

12. Continuous Improvement

{{org_field_name}} will review and improve its modern slavery controls on an ongoing basis.

This may include periodic policy review, incident review, complaints analysis, supplier and client due diligence review, training updates, record sampling, payroll and deduction checks, and worker feedback.

Annual Review

This policy and associated procedures will be reviewed at least annually by the Board of Directors and the Director or Compliance Lead.

It will also be reviewed immediately following any legislative change, regulatory update, material operational change, or if incidents related to modern slavery or labour exploitation arise.

Audit and Feedback

Periodic internal audits may be carried out to support ongoing compliance.

Staff and workers may be invited to give feedback on the implementation of this policy through surveys, supervision, training sessions or other appropriate channels.

13. Policy Review

This policy will be reviewed every 12 months or sooner if there is a change in legislation, regulatory guidance or operational need.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.