1. What is slavery?
1.1 The Modern Slavery Act (MSA) 2015 covers four activities:
|Slavery||Exercising powers of ownership over a person.|
|Servitude||The obligation to provide services is imposed by the use of coercion.|
|Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.|
|Human trafficking||Arranging or facilitating the travel of another person with a view to their exploitation.|
1.2 This policy covers all four activities.
2. How is it relevant to us?
2.1 Slavery is a complex and multi-faceted crime, and tackling it requires all of us to play a part. At first glance, you may think this whole subject is irrelevant to us, but it’s not.
2.2 At a very basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.
2.3 The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
2.4 With this in mind, we need to pay particularly close attention to:
2.4.1 our clients and candidates;
2.4.2 our suppliers;
2.4.3 any outsourced activities, particularly to jurisdictions that may not have adequate safeguards;
2.4.4 cleaning staff; and
2.4.5 corporate hospitality.
3.1 Everyone at Hunter Healthcare Resourcing Limited, from our directors to our employees, have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
3.2 Everyone must observe this policy and be aware that turning a blind eye is unacceptable and simply not an option.
3.3 We will:
3.3.1 maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation;
3.3.2 be clear about our recruitment policy (see Recruitment); 3.3.3 check our Suppliers (see Suppliers);
3.3.4 check our clients and candidates (see clients and candidates);
3.3.5 lead by example by making appropriate checks on all employees, suppliers, clients and candidates to ensure we know who we are working with;
3.3.6 ensure we have in place an open and transparent grievance process for all employees;
3.3.7 seek to raise awareness so that our employees know what we are doing to promote their welfare; and
3.3.8 make a clear statement in paragraph 5 below, that we take our responsibilities to our employees, suppliers, clients and candidates seriously.
3.4.1 listen and be approachable to employees;
3.4.2 respond appropriately if they are told something that might indicate an employee is in an exploitative situation;
3.4.3 remain alert to indicators of slavery (see Identifying slavery);
3.4.4 raise the awareness of our employees, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do; and
3.4.5 use their experience and professional judgement to gauge situations.
We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
3.5.1 keep your eyes and ears open—if you suspect someone (a colleague,
a candidate or someone in our supply chain) is being controlled or forced by someone else to work or provide services, you must report it);
3.5.2 follow our reporting procedure set out in paragraph 7 below if a colleague tells you something you think might indicate they are or someone else is being exploited or illtreated; and
3.5.3 tell us if you think there is more we can do to prevent people from being exploited.
4. The risks
4.1 The principal areas of risk we face, related to slavery and human trafficking, include:
4.1.1 Engaging employees; and,
4.1.2 Recruiting candidates for clients.
4.2 We manage these risk areas through our procedures set out in this policy.
5. Our procedures
5.1 Anti-slavery statement
5.1.1 We make a clear statement that we take our responsibilities to our employees, people working within our supply chain, our candidates, and our clients seriously.
5.1.2 We make this statement through this policy.
5.1.3 Our Statement:
We are a recruitment agency, and therefore at the heart of employment relationships. We acknowledge our responsibility to ensure, to the best of our abilities, that no candidate is subject to slavery or trafficking.
5.2 Supply Chains
5.2.1 We thoroughly check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
5.2.2 We tell the companies we do business with that we are not prepared to accept any form of exploitation.
5.2.3 We will do our best to ensure that all our supplier contracts contain an anti-slavery clause.
5.2.4 We ensure we can account for each step of our supply processes—we know who is providing goods and services to us and we have mechanisms and processes in place to check.
5.3.1 Providing our services to clients and candidates
(a) Our recruitment team follows firm policy and only uses agreed specified reputable recruitment agencies.
(b) To ensure the potential for slavery and human trafficking is reduced as far as possible, we thoroughly check recruitment agencies before adding them to our list of approved agencies. This includes:
(i) conducting background checks
(ii) investigating reputation
(iii) ensuring the staff it provides have the appropriate paperwork (eg work visas)
(c) We keep agents on the list under regular review, at least every 1 year.
5.3.2 Internal recruitment
(a) We always ensure all employees have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.
(b) We always ensure employees are legally able to work in the UK.
(c) We check the names and addresses of our employees (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited).
(d) We provide information to all new employees on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
5.4 If, through our recruitment process, we suspect someone is being exploited, the employee will follow our reporting procedures (See Reporting slavery).
6. Identifying slavery
6.1 There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
6.2 However, the following key signs could indicate that someone may be a slavery or trafficking victim.
6.2.1 The person is not in possession of their own passport, identification or travel documents.
6.2.2 The person is acting as though they are being instructed or coached by someone else.
6.2.3 They allow others to speak for them when spoken to directly.
6.2.4 They are dropped off and collected from work.
6.2.5 The person is withdrawn or they appear frightened.
6.2.6 The person does not seem to be able to contact friends or family freely.
6.2.7 The person has limited social interaction or contact with people outside their immediate environment.
6.3 This list is not exhaustive.
6.4 Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
6.5 If you have a suspicion, report it.
7. Reporting slavery
7.1 Talking to someone about your concerns may stop someone else from being exploited or abused.
7.2 If you think that someone is in immediate danger, dial 999.
7.3 Otherwise, you should discuss your concerns with one of our Directors who will decide a course of action and provide any further advice.
7.4 Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with a director before taking any further action.
We provide training to all of our staff members who are involved in managing recruitment, clients, candidates, and our supply chains.
9. Monitoring our procedures
We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.