Anti-Slavery & Human Trafficking Policy
Anti-Slavery and Human Trafficking Policy
1. Introduction and Policy Statement
ConnectedGroup Ltd ("the Company") is committed to preventing modern slavery and human trafficking in all its corporate activities. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.
This policy is made pursuant to the requirements of the UK Modern Slavery Act 2015 and the Australian Modern Slavery Act 2018 . It outlines the steps the Company is taking to identify, prevent, and mitigate the risks of modern slavery within our business.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to improving our practices to combat slavery and human trafficking.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
2. Scope and Application
This policy applies to all parts of the Company's business. As a recruitment and executive search firm, our primary operations are the provision of permanent and contract recruitment services to clients across various sectors. Our supply chains are relatively simple and primarily include:
- Candidates: Individuals we place into permanent or contract roles with our clients.
- Clients: Organisations to whom we provide recruitment services.
- Third-party service providers: Including IT, marketing, professional services, and office suppliers.
We recognise that the highest risk of modern slavery in our business lies in the potential for forced labour within the supply chains of our clients and in the engagement of contract or temporary workers, particularly those who are migrant workers.
3. Compliance with Legislation
ConnectedGroup Ltd acknowledges its obligations under both the UK and Australian Modern Slavery Acts. We are committed to complying with the specific requirements of each jurisdiction.
3.1 UK Modern Slavery Act 2015 & Australian Modern Slavery Act 2018
In compliance with Section 54 of the UK Act, we will publish an annual Slavery and Human Trafficking Statement outlining the steps we have taken to ensure that slavery and human trafficking are not taking place in our supply chains or our own business. This statement will be approved by our board of directors and published on our website. This document serves as the current statement and will be reviewed annually.
As we have no physical or administrative presence in Australia, we do not need to operate in compliance with the Australian Act, by submission of an annual Modern Slavery Statement to the Australian Government. However, we will use the seven criteria outlined in Section 16 of the Act, covering our structure, operations, supply chains, risks, actions taken, effectiveness of those actions, and consultation processes.
4. Responsibilities
- Board of Directors: The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
- Senior Management: Senior management is responsible for implementing this policy, ensuring adequate resources are allocated, and for dealing with any concerns about modern slavery.
- All Employees: All employees have a responsibility to understand and comply with this policy, and to report any concerns related to modern slavery.
5. Risk Assessment and Due Diligence
We will undertake a regular risk assessment of our business and supply chains to identify areas where there is a higher risk of modern slavery. Our due diligence processes will include:
- Candidate Vetting: We will conduct thorough right-to-work checks for all candidates we place, ensuring they are legally entitled to work and are not being forced to work against their will. We will verify identity documents and be alert to any signs of coercion or deception.
- Client Engagement: We will only work with clients who share our commitment to eradicating modern slavery. As part of our client onboarding process, we will assess the modern slavery risk within their operations and supply chains where possible.
- Supplier Onboarding: We will conduct due diligence on our key suppliers, to ensure they have their own robust policies and procedures for preventing modern slavery.
- Contractual Obligations: We will include anti-slavery and human trafficking clauses in our contracts with clients and suppliers, requiring them to comply with this policy and relevant legislation.
6. Training and Awareness
We will provide training to all our employees, particularly those involved in recruitment and supplier management, to help them understand the risks of modern slavery and to identify and report any concerns. This training will cover:
- The basic principles of the Modern Slavery Acts.
- How to identify the signs of slavery and human trafficking.
- What to do if they suspect a case of slavery or human trafficking.
- Our internal reporting procedures.
We will also raise awareness of modern slavery issues by circulating information and resources to our employees and business partners.
7. Reporting and Whistleblowing
We encourage all our employees, clients, and suppliers to report any concerns about modern slavery in our business or supply chains. We have a whistleblowing policy in place to ensure that anyone who raises a concern in good faith will be protected from any detrimental treatment.
Reports can be made to a line manager, a senior manager, or directly to a Director. All reports will be treated with the utmost confidentiality and will be investigated thoroughly.
8. Monitoring and Review
We will regularly review and evaluate the effectiveness of the steps we are taking to combat modern slavery and human trafficking. This will include monitoring our key performance indicators (KPIs), such as:
- The number of employees who have completed modern slavery training.
- The number of suppliers who did not meet our anti-slavery standards.
- The number of concerns raised and investigated.
This policy will be reviewed annually by the Board of Directors and updated as necessary to reflect changes in legislation, our business, or our risk profile.
9. References
[1] UK Government. (2015). Modern Slavery Act 2015.
[2] Australian Government. (2018). Modern Slavery Act 2018.
