Modern Slavery and Human Trafficking Statement

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 statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes [our OR our Group’s] slavery and human trafficking statement for the financial year ending [DATE].

Organisational structure

We are a provider of Business, Technology & Recruitment Services in multiple sectors.

As a company we work across many geographic regions around the world providing consultancy and delivery of business solutions, technology services and where required staffing solutions whether that be contract, interim or permanent. These solutions are delivered from several our locations including but not limited to UK, Germany, Poland and India.

Our employees are the most important element of our business and the ethics applied to our staff and consultants alike.

We have a global annual turnover of £5m.

Our supply chains

Occasionally we may utilise a supply chain of authorised and vetted partners which all will have been through a strict vetting process and approved partners are the only organisations that staff can work with.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Modern Slavery and Human Trafficking Policy OR we have reviewed our workplace policies and procedures to assess their effectiveness in identifying and tackling modern slavery issues.

Our Modern Slavery and Human Trafficking Policy OR our workplace policies and procedures demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Please see our workplace policies and procedures document in the employee handbook or contact the partner management team for any documents relating to Modern Slavery & Human Trafficking Statement if you wish to know more about the requirements for partners.


As part of our initiative to identify and mitigate risk we outline due diligence procedures or other relevant steps taken.

We have in place systems to:

  • Identify and assess potential risk areas in our supply chains.
  • Mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • Monitor potential risk areas in our supply chains.
  • Protect whistle blowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have in place a supply chain compliance programme.

Part of this process is all suppliers must be approved by the partner management team and countersigned by one of the directors of the company. The partner management team will follow a strict process of audit and supplier agreements which must be concluded before any work or engagement can proceed.

We have a dedicated compliance team, which consists of representatives OR involvement from the following departments:

  • Legal
  • Audit and Compliance
  • Human Resources
  • Procurement
  • Sales.

The compliance team is led by Mr Sundip Rabheru.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide or intend to provide training to our staff. We also require our business partners to provide training to their staff and suppliers and providers.

Our effectiveness in combating slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Incorporate requirements for suppliers to work to prevent slavery and human trafficking into our standard terms and conditions for suppliers
  • Implement a procurement risk matrix and assessment process that includes slavery and human trafficking, in order to assess the risk areas of our supply base on an ongoing basis
  • Integrate the topic of slavery and trafficking into our supplier engagement processes for sustainability
  • Execute an awareness-building communications campaign on slavery and human trafficking, and the requirements of the Modern Slavery Act

These will be reviewed on an annual basis.


In addition to the above we have an external consultancy who can advise and monitor such issues namely Peninsular which is detailed in the employee handbook.

Further steps

Following a review of the effectiveness of the steps we have taken to ensure that here is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking which will include but not limited to a directors review of all partners, an annual audit to ensure all documentation and reviews have been completed of suppliers and training to staff as and when required.

Date: 13TH June 2017