Modern Slavery Policy
1. At GetGroupUK, we are committed to protecting and respecting human rights and have a zero tolerance approach to slavery and human trafficking in all its forms. This statement is made pursuant to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps the GetGroupUK has taken and will take in relation to slavery and human trafficking.
2. GetGroupUK structure and activities
GetGroupUK recognises that all businesses have an obligation to prevent slavery and human trafficking and will do all in its power to prevent slavery and human trafficking within its business and within the supply chains through which it operates.
Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. As the world’s leading recruitment experts, we take our responsibility for supplying staff extremely seriously and are aware of the potential for being targeted by traffickers and unlicensed gangmasters.
This statement focuses specifically on GetStaffedUK compliance with the Modern Slavery Act 2015 (the Act) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within the organisation or its supply chains. One of our Company’s most valuable assets has always been its reputation for integrity and fairness. Maintaining this reputation within our market is an essential to our continued success.
3. Our commitment
We recognise that modern slavery is a significant global human rights issue and includes human trafficking, forced and bonded labour, child labour, domestic servitude, and sex trafficking. We are committed to protecting and respecting human rights and have a zero-tolerance approach to slavery and human trafficking in all its forms. We will act ethically and with integrity in all our relationships, and use all reasonable endeavours to take action directly and to influence others to ensure slavery and human trafficking is not taking place, wherever we can do so.
Our Policies set out our commitment to workplace rights at the GetGroupUK. Our Dignity and Respect Policy promotes an enabling and inclusive environment in which all members of the GetGroupUK community are treated with dignity and respect, and bullying, harassment and discrimination are known to be unacceptable. We are committed to fair, progressive and ethical working practices and have signed the Scottish Business Pledge. We have a Whistleblowing Code of Practice which enables staff to report improper conduct or unethical behaviour.
We have a number of policies which govern our relationships with business. We have a published GetGroupUK Procurement Policy which displays our principles and practices in the acquisitions of goods, services and works, and outlines how we will take steps to ensure an ethical procurement approach.
4. Modern slavery risks in our supply chains and other areas
We buy a wide range of goods and services, furniture and stationery, electronics (computers, audio visual, etc.), food and catering supplies, travel services, books and printing, and waste and recycling services, and do so in accordance with public procurement law. A large proportion is bought through frameworks established by collaborative consortia.
While the risks of modern slavery in our direct activities is likely to be low, we recognise that there are risks through the goods and services that we procure.
5. Steps we have taken and processes in place – to identify and mitigate modern slavery risks:
Preventing modern slavery on our own premises. We are rigorous in checking that our staff have the right to work in the UK. Where it is necessary to hire agency workers or contractors, our staff are directed to specified, reliable agencies who have met GetGroupUK’s rigorous procurement procedures regarding their business and employment policies and practices. For example, agencies are asked to identify any sub-contractors and to promote ‘fair work’ practices, as appropriate.
Identifying and assessing potential risk areas in our supply chains. In 2017 we carried out research specifically on modern slavery risks that could affect any aspect of GetGroupUK operations (on our own premises, in supply chains, in waste disposal, in our partnerships with others). We identified and engaged with relevant across the institution through a workshop and further meetings and established a small cross-department working group on modern slavery.
Excluding any suppliers which have been convicted of offences of child labour or other forms of to the subject of a conviction by final judgment within the last five years of any offence under Part 1 of the Human Trafficking and Exploitation (Scotland) Act 2015 or under any provision referred to in the Schedule to that Act. Any bidders with such conviction will automatically be excluded from the bidding process, unless they can sufficiently demonstrate reliability of changes to their practices.
Monitoring risks and working with others on mitigation strategies. When relevant suppliers sign up to the APUC Supply Chain Code of Conduct (which specifies that suppliers shall not use ‘forced, involuntary or underage labour’) and associated policies that are aligned to specific commodity areas, we expect them to conform. Through the APUC’s SUSTAIN database, suppliers can provide details of measures they take in relation to modern slavery in their supply chain, including any third-party accreditations and assessments to evidence this.
Where risks have been identified, we work with APUC or other consortia, or directly, to raise social responsibility questions including human rights issues at contract management meetings with our key suppliers, assess publicly available reports from companies, and follow-up on any concerns we identify.
In 2017, we engaged with our three main Information and Communication Technology (ICT) suppliers on a range of social responsibility and sustainability issues including forced labour and conflict minerals.
Listening to and protecting whistle-blowers. GetGroupUK adheres to The Public Interest Disclosure Act 1998 and implements its own Whistleblowing Policy regarding concerns about corruption, fraud or other malpractices within the GetGroupUK.
Taking action if modern slavery cases are found. If on site, any alleged violation of human rights will be fully investigated and appropriate disciplinary action will be taken against any member of staff found to have acted unethically and in breach of GetGroupUK’s commitment to human rights. If in our supply chains, the GetGroupUK in certain cases will have the right to terminate contracts where serious violations are discovered. In most cases we seek to engage, improve, highlight and recognise our responsibility to support the identification, mitigation and eradication of modern slavery in our supply base.
Assessing our effectiveness in combating slavery and human trafficking. We seek to continually improve our approach. In 2017 we undertook research to look at approaches within and outside of the sector.
If you have any queries about the contents of the policy, please contact GETGROUPUK on 01772 921107, email info@GetGroupUK.co.uk or visit our website www.GetGroupUK.co.uk
Monitoring and Review Policy reviewed 23/01/2018 by Tom Havlin
This policy will be reviewed again 23/01/2019 by Tom Havlin or any appropriate policy or compliance manager.