The Modern Slavery Act
The Modern Slavery Act received royal assent on 26/4/15. The Act consolidates slavery and trafficking offences and introduces tougher penalties and sentencing rules. A new Transparency in Supply Chains clause requires all organisations with a turnover of or over a threshold of £36 million to produce and publish a slavery and human trafficking statement each financial year (effective – with some variation depending on financial year ends – from 31/3/16). This statement should be displayed on the business’s website. Those TEAM Members meeting this threshold will be required to produce such a statement in their own right, but many SME TEAM Members may act as a second tier supplier to a larger agency or may be on a PSL to a client, either of whom may seek reassurance under this Act from their chain of suppliers. Whilst such smaller recruitment businesses will not be required to produce a statement, many may believe that making such a statement will demonstrate their ethical and transparent approach to improving professional standards, protecting vulnerable workers and preventing severe human rights violations. More detailed guidance can be found:
There is no requirement about the layout or specific content of such a statement and each business can determine how much detail they provide. Whilst the guidance references above may assist, good business practise suggests that the statement should clearly and simply demonstrate your business’s approach to the Act and any and all steps taken to ensure compliance. An example layout may include the following headline points:
- Organisational structure, your business and its supply chains.
- Your policies in relation to slavery and human trafficking in your business and supply chains
- Your due diligence processes in relation to it including areas where there’s a particular risk and steps taken to manage it.
- How effective you’ve been at ensuring that slavery and human trafficking is not taking place in your business or supply chains
- The training about slavery and human trafficking available to your staff.
Some generalised example copy has been inserted to provide TEAM Members with a guide, but given every business will be different this should be personalised and expanded upon as appropriate – and needless to say, you should only say something if you’re sure that it is true in relation to your business. Any member of TEAM Legal are also available to assist and advise at appropriate TEAM discounted rates.
INTRODUCTION/STATEMENT FROM THE MANAGING DIRECTOR
All reputable businesses have a moral and legal obligation to assist in the eradication of the abuse of any individual and the protection of vulnerable people. We encourage any client or member of staff to report any concerns and we pledge that management will take all reasonable steps to act upon such information. All matters relating to the Modern Slavery Act 2015 (the Act) within our business are the responsibility of David Grzywna
NATURE OF OUR BUSINESS
We are a recruitment and employment business based in the North West and we provide recruitment to the following sectors:
- Education (Primary, Secondary & Higher Education)
- IT & Finance
TRAINING AND AWARENESS
We are members of a UK network of professional recruiters (TEAM) who amongst other matters also provides training and compliance services. Apart from assisting their Members with guidance they offer specific courses with regard to the Act. As part of our induction process all new members of staff are briefed on the requirements of the Act.
When we engage with any new Client or Supplier we supply them with a copy of our statement and seek assurances from them that their business is aware of the Act and that it is suitably compliant.
When we engage with a job seeker we provide them with guidance as to their rights and the nature of our services and we would encourage them to report any concerns or infringements enacted by an employer.
At least annually but usually every 6 months we:
Conduct an adhoc review of at least 50 of our Clients.
Conduct an adhoc review of at least 50 of our Suppliers.
Conduct an adhoc review of at least 50 of our supplied workforce.
Conduct an adhoc review via our payroll of supplied workers.
Raise the matter with our employees at their individual review.
This statement is made in accordance with Section 54(1) of the Act and constitutes our slavery and human trafficking statement for the current financial year.
Office of the Independent Anti-Slavery Commissioner
0203 513 0475
Modern Slavery Helpline
0800 0121 700
ENGLAND and WALES
The Salvation Army
0300 303 8151
Trafficking Awareness Raising Alliance (TARA)
0141 276 7724
Migrant Help (Male) 013 0420 3977
Women’s Aid 028 9024 9041