Modern Slavery Statement
Modern Slavery Statement
Due to the scope of our business The Staffing Group recognises that we may be at risk of Modern Slavery (slavery, servitude, forced labour and human trafficking). The following statement has been published in accordance with the Modern Slavery Act 2015 and sets out the steps taken by The Staffing Group during the year end of December 2018 to prevent modern slavery and human trafficking in its businesses and supply chains.
The Staffing Group operates from over 112 group locations across the UK and are one of the top 4 largest suppliers of contractual labour pay rolling at peak, in excess of 25,000 temporary colleagues. The Staffing Group is made up of the following companies:
Single Resource is an on-site managed service recruitment business, providing large scale volume temporary recruitment solutions within the warehouse, distribution and food manufacturing industries. Operating from 72 locations across the UK, they are one of the top 4 largest privately owned suppliers of contract labour and regularly payroll in excess of 15,000 temporary colleagues per week.
ep professional recruits within 10 specific candidate sectors and can offer temporary, permanent, interim and contract solutions across the UK. With a team of specialist consultants and expert resourcers working from our midlands hub, they use the latest technology in terms of candidate attraction. Specialisms include sales & marketing, HR, logistics, procurement, supply chain, finance and technical & engineering.
Extra Personnel is a specialist provider of industrial, transport, commercial, automotive and skilled & technical recruitment operating from over 40 UK locations.
Extra Drivers is our specialist driving division and are a recruitment process outsourcing (RPO) company specialising in managed service provision on a nationwide basis. Extra Drivers provides clients with a bespoke service for the supply of volume transport labour.
Extra Personnel Automotive Limited provide onsite managed services, remote and branch lead recruitment models for multiple site locations across the UK within the automotive sector.
As a group we are committed to working alongside any organisation which will support in the overall aim of reducing modern slavery within our supply chain and across the UK.
Exposure to Modern Slavery
We have considered the exposure of The Staffing Group to modern slavery risks, taking in to account:
Labour requirements for end users are volatile with staffing requirements increasing suddenly without prior notice;
Recruitment of low skilled labour with potentially limited or no English speaking; and
Requirements to increase our supply chain can occur in peak times resulting in the use of 2nd tier labour providers.
As a result of the factors above we consider the risk of modern slavery occurring within our supply chain population to be high.
Policies and Procedures
We will not tolerate or condone any form of exploitation and as such, have implemented both a Preventing Hidden Labour Exploitation Policy and a Forced Labour and Ethical Policy. This sets out the responsibilities of each individual within the business to identify and report any suspicions of potential cases of exploitation. All reports will be fully investigated and appropriate remedial actions taken.
Procedures have been put in place to support internal employees in identifying potential hidden labour exploitation.
Collaborative processes are developed and implemented alongside our clients where possible to strengthen our ability to identify and prevent potential cases of modern slavery.
Policies and procedures are developed and reviewed regularly by the Quality and Compliance Department alongside the relevant subject matter expert, and signed off at Director level.
We expect all 2nd tier labour suppliers to adhere to applicable national laws and standards in relation to labour practices and human rights, including the Modern Slavery Act 2015.
Due Diligence and audits
We understand that our biggest exposure to Modern Slavery is within the recruitment process and undertake to raise awareness within the business in order to identify any potential situations from the first instance.
Due diligence is expected throughout the whole recruitment process and throughout the workers employment within the business. Reports are monitored to identify houses of multiple occupancy, dual bank accounts and mobile numbers, with all workers listed on the dual address report receiving the ‘Stronger Together Private Home Rental Guidance’ and the relevant contact details should they require further advice. Welfare meetings are held where required as an additional check to highlight “Alert Flags” of exploitation.
All sites / branches and 2nd tier suppliers are subject to due diligence checks in the form of compliance audits conducted by the Quality and Compliance Department.
These audits assess compliance with the relevant legislation / regulations and are, amongst other things, intended to identify any Modern Slavery practices or areas of potential risk to the supply chain. Procedures are reviewed to eliminate risk and gain compliance across all business locations.
Due diligence on 2nd Tier Labour Providers
All 2nd tier labour providers are subjected to a compliance check from the Quality and Compliance Department prior to supply, this is to ensure their business is fit and proper to supply into our business and that they have sufficient processes and policies in place to adhere to the applicable national laws and standards.
Annual audit inspections are carried out on any 2nd tier labour providers who continuously supply by the Quality and Compliance Department. Additional inspections will be carried out should any concerns arise throughout supply.
Prioritised suppliers are also required to complete a self-assessment questionnaire on an annual basis to review how they are applying and adhering to the applicable national laws and standards, including questions on human rights policy and procedures, as well as labour practices and HSE. The output of these assessments are assessed by the Quality and Compliance Department to monitor for areas of potential risk.
If a supplier’s practices are found to be unsatisfactory or non-conformant, we will arrange a full audit inspection and address the outcome on a case by case basis, seeking external advice where appropriate.
We are committed to working with our suppliers to ensure they have appropriate ethical and responsible policies and processes in place and support them in closing any areas of risk these checks may identify.
Training and Awareness
All new internal employees are invited to attend a company induction which will provide information on the business, our values, policies and procedures and information on Modern Slavery. There is also the ability to use an online training platform which enables all new starters to the business or those wishing to refresh their knowledge to complete a
Stronger Together training module.
Workshops are rolled out across the business in order to upskill our current internal employees or offer further support where required.
Bespoke training is given to those locations identified at higher risk, using previous cases and investigations as training material.
All attendees to either an induction or workshop will be asked to commit to preventing labour exploitation by signing a “Recruiter Compliance Principles” document which is retained on their personal file.
Flexi-Workers are shown the Stronger Together “Daniel and Weronika” video, along with leaflets and posters available to highlight the situation and how the individual can report their suspicions.
The “Lured by a job, trapped in forced labour” video from the International Labour Organisation is shown in reception areas, where possible to highlight the situation and notify applicants that we do not tolerate any form of exploitation.
Attendance to roadshows and workshops provided by external companies such as the Association of Labour Providers Stronger Together and the Gangmaster Labour and Abuse Authority is promoted to all top level management in order to maintain knowledge and distribute across the business.
Every 6 months a Modern Slavery Action Group is held centrally with designated representatives across all areas where areas of concern are discussed, ideas for improvement and potential opportunities for raising awareness and improving our Modern Slavery activities.
Additional Activities and Events
In 2016 the business conducted an awareness event during Anti-Slavery Week which saw members of the business situated within the Mander Centre, Wolverhampton, alongside a “Gift Box” which aims to raise awareness of forced labour with over 1000 leaflets distributed to the local community. With 2017 seeing a social media campaign to raise
awareness and collaborative working within a ‘Business in Combat’ group alongside local authorities and NGO’s amongst others to combat modern slavery.
In order to ensure any potential victims of exploitation are dealt with in the correct manner and any investigations are conducted effectively without damaging evidence, key members of the business have achieved a Certificate in Professional Development for Investigating Modern Slavery. This course has been developed by the GLAA in conjunction
with Derby University and provides guidance on how to conduct an investigation effectively whilst protecting potential victims.
In June 2018 a group of representatives from the business took part in a 10k run for Hope for Justice raising awareness and funds which were donated to Hope for Justice.
2018 also saw Single Resource become the first recruitment agency to become a business partner of Bright Future. Bright Future is an initiative created by the Co-op to offer paid work placements leading to a non-competitive job interview for survivors of modern slavery. The Staffing Group have 2 clients signed up as a placement location for the scheme and are waiting for the first candidate to be placed in 2019.
The Staffing Group commit to ensuring we operate towards the best practices at all times. Evidence of this can be seen through the Stronger Together website, which shows we have taken the relevant steps to become a Business Partner of Stronger Together since 2015.
By continually assessing the risks of any form of modern slavery taking place within our operations and implement processes and polices to try to minimise these risks, we are able to support the relevant government authorities in reporting any identified situations, and as such protect our business, our clients businesses and first and foremost, our workers.
This statement has been made in accordance with the reporting requirements of Clause 54, Part 6 of the UK Modern Slavery Act for the year ending 31 December 2019.
This statement was approved by: