Modern Slavery Act 2015
As a UK recruiter HR Group Ltd realise that we are in at the front line of the recruitment process and play an important role in tackling the problem of Slavery and Human Trafficking.
HR Group Ltd commit to developing and adopting a proactive approach to tackling Slavery and Human Trafficking.
“Slavery” is where ownership is exercised over a person, where individuals are coerced into providing their services or do so under threat of a penalty. “Human trafficking” covers arranging or facilitating the travel of individuals with a view to exploiting them. It is understood that it is often well hidden by the perpetrators, with victims if they perceive themselves as such, reluctant to come forward.
Coverage
This policy is applicable to all offices and operations within the HR Group Ltd.
Responsibility
Responsibility to ensure the policy commitments are upheld, including training, updates and auditing lies with HR Group Ltd with overall responsibility lying with HR Group Ltd’s board of directors.
In our commitment to the Preventing Slavery and Human Trafficking HR Policy, we have appointed local representatives in the form of our Branch and Onsite Managers. Our managers are tasked with the responsibility of upholding the policy at a local level. Ensuring all staff involved in the Recruitment, Managing and Supply of Contractors on a day to day basis are compliant.
Policy Commitments
HR Group Ltd shall:
1. Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
2. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are aware of issues around Slavery and Human Trafficking exploitation and signs to look for and have signed appropriate Compliance Principles
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
5. Adopt a proactive approach to reporting suspicions of Slavery and Human Trafficking to the Gangmasters Licensing Authority and police.
6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through a variety of formats such as workplace posters, worker leaflets, induction, other training.
7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities
9. Ensure that our supply chain, including second tier arrangements are fully aware of the Modern Slavery Act 2015 and compliant with the requirements stated within the Act.
Internal Auditing
HR Group Ltd have implemented a number of internal compliance auditing processes across the business.
The sectors believed to be most affected by Slavery and Human Trafficking are construction, agriculture, textile, security, food processing and packaging, constituting much of HR Group Ltd core business.
As a result of this, the compliance team have built in a number of processes to their audits and our standard business practices which have strengthened our links with external bodies to ensure industry issues including illegal working prevention and labour exploitation are addressed through:
• Improved knowledge and understanding of illegal working checks
• Remote audits reports generated weekly from our integrated IT systems which enable volume analysis of worker records, including duplicate postal / email address and banking information to identify and alert us to suspect activity
• To review agreements, processes and audit any third party suppliers to ensure the wellbeing of workers provided