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MODERN SLAVERY POLICY

Connect Appointments commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

Hidden labour exploitation is exploitation of job applicants and workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.

Coverage: Company Wide

Review Period: Annual

Responsibility: The directors of Connect Appointments hold overall responsibility for the implementation of this policy for all consultants. Consultants will endeavour to adhere to all aspects of this policy whilst carrying out their duties.

 

POLICY COMMITMENTS

Connect Appointments 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 trained to be aware of issues around third-party labour 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 hidden worker exploitation to the Gangmasters Licensing Authority and police.
  6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through (list formats e.g. in 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. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.

For more information contact our Human Resource department at hr@connectappointments.co.uk

Reviewed: 27th March 2024 by William Sim

 

Resources on combating modern slavery can be found on the UK Governments website. Other organisations include antislavery.org and the National Crime Agency.

MODERN SLAVERY STATEMENT

This statement is made as part of Connect Appointments’ commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (“the Act”). It summarises how Connect Appointments operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act, and relates to the financial year December 2022 to November 2023. It was approved by Connect Appointments’ Directors on 30th April 2024.

Denise Harper, Director

1. OUR BUSINESS

Connect Appointments is a limited company operating in the recruitment sector. We provide temporary, contract and permanent recruitment solutions in a variety of sectors, including production & manufacturing, logistics, driving & transport, hospitality, administration, and more.

Connect Appointments is an independent business.

1.1. Who we work with

The companies that we work with are located in the United Kingdom, and operate in a wide variety of industries, including: logistics, production & manufacturing, executive & management, administration, and construction. The workers we supply also live in the United Kingdom.

1.2. Other relationships

  • As part of our business, we also work with the following organisations:
  • the Gangmasters & Labour Abuse Authority (GLAA)
  • Stronger Together
  • Sedex
  • JobsAware
  • Association of Labour Providers
  • the Recruitment and Employment Confederation

2. OUR POLICIES

Connect Appointments has a modern slavery policy, available at: https://www.connectappointments.co.uk/modern-slavery-policy/
In addition, Connect Appointments has the following policies which incorporate ethical standards for our staff and suppliers:

  • Complaints & Whistleblowing Policy
  • Health & Safety Policy
  • Information Handling Policy
  • Anti-bullying & Harassment Policy
  • Recruitment of Ex-Offenders Policy
  • Social & Ethical Policy

2.1. Policy development and review

Connect Appointments’ policies are established by our Directors, based on advice from HR professionals, industry best practice and legal advice. We review our policies annually or as needed to adapt to changes.

3. OUR PROCESSES FOR MANAGING RISK

In order to assess the risk of modern slavery, we use the following processes internally:

  • Regular internal audits are carried out by a member of Head Office staff, ensuring that each branch has completed the legally required right-to-work checks of candidates
  • When registering candidates, their details are automatically compared against the rest of our workers on our internal database, to identify cases of duplicate National Insurance numbers, duplicate postcodes and duplicate bank account details, all of which can be a sign of modern slavery
  • We take supplier audits seriously, using them as an opportunity to identify further areas of improvement in our of modern slavery policy and processes
  • We look carefully for any International Labour Organization indicators of forced labour, including: abuse of vulnerability, deception, restriction of movement, isolation, physical/sexual violence, intimidation/threats, retention of right-to-work documents, withholding of wages, debt bondage, abusive working/living conditions, and excessive overtime

After due consideration, we have identified the following potential risks in our supply chain:

  • Due to differing employment practices in different countries, foreign nationals may not be aware of the signs that they are becoming a victim of modern slavery, for example in some countries employers will retain right-to-work documents and not return them to a worker
  • Due to the often voluminous nature of recruiting for manufacturing and logistics roles, it can be more likely, in theory, that warning signs of modern slavery will be overlooked

Additionally, we have taken the following steps to minimise the possibility of any problems:

  • We require the businesses we work with to adopt policies and procedures consistent with our Modern Slavery policy
  • We collaborate with the businesses we work with to improve standards and transparency across our supply chain
  • We work with a number of organisations, including the Gangmasters & Labour Abuse Authority, Association of Labour Providers and Stronger Together, in order to combat the risk of modern slavery and human trafficking

Our staff are encouraged to bring any concerns they have to the attention of management.

4. OUR PERFORMANCE

As part of monitoring the performance of Connect Appointments, we track the following general key performance indicators:

  • Frequency of engagement with authorities that relate to modern slavery, such as GLAA, the police and relevant NGOs
  • Number of duplicate bank accounts, National Insurance numbers and addresses identified in the registration process

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our Directors:

  • The amount of time spent on audits, re-audits, spot checks, and related due diligence
  • The level of modern slavery training and awareness amongst our staff

We carefully consider our indicators, in order to ensure that we do not put undue pressure on the businesses we work with that might increase the potential for risk.

5. OUR TRAINING

All of our staff receive training and support that is appropriate to their role. In particular:

  • All Connect Appointments staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management. This includes a detailed induction presentation provided by Stronger Together.

As part of this, our staff are encouraged to discuss any concerns that they have.