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Slavery and Human Trafficking Act

As a UK leading industrial recruiter gap personnel realise that we are in at the front line of the recruitment process and play an important role in tackling the problem of Slavery and Human Trafficking.
Gap personnel commit to developing and adopting a proactive approach to tackling Slavery and Human Trafficking.
“Slavery” is where ownership is exercised over a person, where individuals are coerced into providing their services or do so under threat of a penalty. “Human trafficking” covers arranging or facilitating the travel of individuals with a view to exploiting them. It is understood that it is often well hidden by the perpetrators, with victims if they perceive themselves as such, reluctant to come forward.

Coverage
This policy is applicable to all offices and operations within the gap personnel group, inclusive of Kerr Multilingual, Driving Force, gap Onsite and gap Technical.

Responsibility
Responsibility to ensure the policy commitments are upheld, including training, updates and auditing lies with gap personnel’s Compliance Team with overall responsibility lying with Mark Roberts, gap personnel Managing Director.
In our commitment to the Preventing Slavery and Human Trafficking HR Policy, we have appointed local representatives in the form of our Branch and Onsite Managers. Our managers are tasked with the responsibility of upholding the policy at a local level. Ensuring all staff involved in the Recruitment, Managing and Supply of Contractors on a day to day basis are compliant.

Policy Commitments
gap personnel shall:
1. Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
2. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are aware of issues around Slavery and Human Trafficking exploitation and signs to look for and have signed appropriate Compliance Principles
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
5. Adopt a proactive approach to reporting suspicions of Slavery and Human Trafficking to the Gangmasters Licensing Authority and police.
6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through a variety of formats such as workplace posters, worker leaflets, induction, other training.
7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities
9. Ensure that our supply chain, including second tier arrangements are fully aware of the Modern Slavery Act 2015 and compliant with the requirements stated within the Act.

Internal Auditing
In our aim to be recognised as the largest and most profitable independent industrial recruitment agency in the UK. gap personnel have implemented an internal compliance team to conduct stringent auditing processes across the business.
The sectors believed to be most affected by Slavery and Human Trafficking are construction, agriculture, textile, security, food processing and packaging, constituting much of gap personnel’s core business.
As a result of this, the compliance team have built in a number of processes to their audits and our standard business practices which have strengthened our links with external bodies to ensure industry issues including illegal working prevention and labour exploitation are addressed through:
• Improved knowledge and understanding of illegal working checks including the implementation of MRZ checker systems and working closely with UKBA and local immigration teams
• Remote audits reports generated weekly from our integrated IT systems which enable volume analysis of worker records, including duplicate postal / email address and banking information to identify and alert us to suspect activity
• To conduct formal GLA / Hidden Labour exploitation interviews with our temporary workers during branch and onsite audits – with a commitment to completing 150 per annum throughout our network including any workers supplied via third party agencies
• To informally issue online confidential GLA / Hidden labour exploitation questionnaires to 10,000 workers per annum
• To review agreements, processes and audit any third party suppliers to ensure the wellbeing of workers provided
• Sourced and implemented a multi lingual Confidential Helpline process by which issues can be raised confidentially by phone, email or in writing to our Branch, Onsite Managers or a member of our Compliance team

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