Anti-Slavery Policy

Introduction

This policy sets down Perfect Recruitment’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty of care to be alert to risks, however small. Staff are expected to report any concerns and management to act upon them.

The Modern Slavery Act (MSA) 2015 covers four activities:

This policy covers all four activities.

How is it relevant to Perfect Recruitment?

Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. At a very basic level, preventing exploitation and human trafficking and protecting our workforce and reputation makes good business sense.

The MSA 2015 recognises the important part businesses can and should play in tackling slavery. With this in mind, we need to pay close attention to:

• Our supply chain
• Any outsourced activities, particularly to jurisdictions that may not have adequate safeguards
• Cleaning and catering suppliers
• Corporate hospitality

Responsibilities

Perfect Recruitment, our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treat fairly and with dignity.

Everyone must observe this policy and be aware that turning a blind eye is unacceptable and not an option.

We will:

• Maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation
• Be clear about our recruitment policy
• Check our supply chains
• Lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us
• Ensure we have in place an open and transparent grievance process for all staff
• Seek to raise awareness to that our colleagues know what we are doing to promote their welfare
• Make a clear statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place in our supply chains and to demonstrate that we take our responsibilities to our employees and our clients seriously.

Managers will:

• Listen and be approachable to colleagues
• Respond appropriately if they are told something that might indicate a colleague, or any other person is in an exploitative situation
• Remain alert to indicators of slavery
• Raise the awareness of our colleagues by discussing issues and providing training so that everyone can spot the signs of trafficking and exploitation and know what we do
• Use their experience and professional judgement to gauge situations

Colleagues:

We all have responsibilities under this policy and whatever your role or seniority you must:

• Be aware – if you suspect someone is being controlled or forced by someone else to work or provide services, follow our reporting procedure.
• Follow the reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated.
• Tell us if you think there is more, we can do to prevent people from being exploited.

The Risks

The principal areas of risk we face, related to slavery and human trafficking include:

• Supply chains
• General recruitment

Our Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This policy affirms its intention to act ethically in our business relationships.

The following policies also set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.

Corporate Social Responsibility (CSR) policy – the Company’s CSR policy sets down how we work responsibly with suppliers and local communities.

Due Diligence Processes

The Company undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear on expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Identifying Slavery

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim:

• The person is not in possession of their own passport, identification or travel documents
• The person is acting as though they are being instructed or coached by someone else
• They allow others to speak for them when spoken to directly
• They are dropped off and collected from work
• The person is withdrawn or they appear frightened
• The person does not seem to be able to contact friends or family freely
• The person has limited social interaction or contact with people outside their immediate environment

Please note, this list is not exhaustive.

A person displaying a number of the above may not necessarily be a victim of slavery or human trafficking however you will often build up a picture of the person’s circumstances which may indicate if something is not quite right. If you are suspicious, we encourage you to report it.

Reporting Slavery

Talking to someone about your concern may stop someone else from being exploited or abused. If you think that someone is in immediate danger, call 999. Otherwise, you should discuss your concerns with the Director who will decide a course of action and provide further advice.

Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the protentional victim at risk, so it is important that in the absence of immediate danger, you speak to the Director before taking any further action.