JAC RECRUITMENT INTERNATIONAL LTD
INTRODUCTION
JAC RECRUITMENT INTERNATIONAL LTD and its subsidiaries (“JRI”) recognises that slavery, forced labour and human trafficking in all its forms is an issue of global concern and is committed to the practice of eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
We believe that all businesses play a vital role in preventing slavery and human trafficking and we take our responsibilities in that regard very seriously. This statement summarises the steps that JRI takes to ensure that our activities are free from slavery and human trafficking.
Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. JRI is committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains. This policy is pursuant to the Modern Slavery Act 2015 (UK) “the Act”.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Act. As part of this process, we have undertaken a review of our supply chain to identify and assess potential risk areas and maintain a register detailing the same.
We expect high standards from all our subcontractors, suppliers and other business partners and have made this a contractual term in our agreements with significant suppliers wherever possible.
1. OUR POLICIES AND CONTRACTS
JRI has a zero-tolerance approach to any imposition of, or connection to, modern slavery and human trafficking.
Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in respect of all our staff and business relationships. In conjunction with our Whistleblowing Policy and Anti-Bribery and Corruption Policy, it encourages all our employees to voice any concerns relating to the activities of our own organisation or our supply chain.
We also have a number of policies prohibiting harassment, discrimination and victimisation which provide our employees access to further channels for raising concerns.
Our contracts of employment and contracts for our temporary/contract workers comply with relevant local laws and ensure that individuals are entitled to at least the legal minimum (including rights in relation to hours, pay and termination of the contract).
We have appropriate policies and processes for conducting background checks on candidates (including their eligibility to work).
2. OUR SUPPLY CHAINS
Our suppliers (including other recruitment agencies that we may use from time to time) are reputable and must pass our checks. We expect our suppliers to have the same standards in terms of ethics and legal compliance – including their own policies on modern slavery and anti-human trafficking. Our larger supplier contracts specifically state that suppliers must comply with applicable laws.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
3. OUR DUE DILIGENCE PROCESSES
During the course of 2022, we will introduce a Supplier Due Diligence Checklist and a Supplier Code of Conduct which, amongst other things, communicate our high ethical standards and expectations to Suppliers along with our zero-tolerance approach to slavery.
On review of Supplier contracts, our Compliance Team also assess the risk of each Supplier. Any Supplier who is identified as being medium or high risk is carefully reviewed and, where appropriate, further measures are put in place.
We take the supply of contract and permanent personnel seriously and our Compliance Team carefully reviews all contractual terms between our company and our Clients. This helps to ensure that particularly our contract candidates will be working in a safe, professional environment and that their working hours will be monitored by way of a formal timesheet process.
We meet with prospective candidates (wherever reasonably possible) and carry out a number of checks on prospective employees and candidates (whether they are to be placed with clients or for our own internal recruitment purposes) as part of our due diligence processes. Depending on the nature of the relationship held we:
conduct Right to Work and reference checks on our employees and candidates as applicable
check that temporary and contract workers who we payroll have their own bank account into which they can be paid and receive pay that is compliant with the relevant legislation in the applicable jurisdiction (including but not limited to The Agency Workers Regulations 2010 (Agency Regulations))
engage temporary and contract workers via a formal contract which is compliant with relevant legislation in the applicable jurisdiction (including but not limited to the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and Agency Regulations in the UK)
comprehensively vet and audit umbrella companies to ensure that those on our preferred supplier list comply with all relevant laws in the applicable jurisdiction relating to employment and taxation
4. OUR RISK ASSESSMENT
Overall, we consider that the nature of the recruitment services that we provide, and the sectors within which we operate, mean that our risk of slavery is lower than in other sectors. However, our Board will continue to monitor the risk and revisit this assessment on a yearly basis.
5. MEASURING EFFECTIVENESS
We are committed to adopting best practice and will continue to monitor the effectiveness of our controls and systems and to make improvements and enhancements wherever possible.
6. OUR TRAINING FOR STAFF
We understand the importance of training employees to enable them to be able to identify slavery. During the course of 2022, we will introduce annual training for our employees on slavery to further enhance their understanding of this area and their ability to identify signs of slavery and raise concerns.
This statement is made pursuant to the Modern Slavery Act 2015 and is for the current financial year. This statement applies to all our subsidiaries and shall be reviewed annually. Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Stephen Blundell - Chief Financial Officer
on behalf of JAC Recruitment International Ltd and its subsidiaries
May 2022