Introduction
This statement sets out SSG Recruitment Partnerships actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the Company's financial year.
As part of its recruitment activities, the company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The company is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Company structure and supply chains
This statement covers the activities of SSG Recruitment Partnerships Ltd:
SSG Recruitment Partnerships Limited is committed to supplying temporary and permanent staffing solutions. As a result we speak with and place a large number of candidates on a regular basis. These candidates come from a variety of countries outside the United Kingdom.
High-risk activities
The following activities are considered to be at high risk of slavery or human trafficking:
As a result of the sectors we deal in, we supply certain industries we believe to be to a Higher Risk of Modern Day Slavery. The main High Risk identified is that of the supply of large staff volumes to the low or unskilled job markets such as Food Production. We believe this is a High Risk area simply down to the volume of staffed processed on occasions at short notice to fill assignments. Also when recruiting large numbers, multiple Agency Workers will provide details of friends or relatives they would like us to register and employ.
Responsibility
Responsibility for the company's anti-slavery initiatives is as follows:
- Policies: Ani Anaz
- Risk assessments: Ani Anaz
- Investigations/due diligence: Ani Anaz
Relevant policies
The company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Employee code of conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct and ethical behaviour when managing its recruitment activities.
- Recruitment Procedure
- The company ensures that each engagement takes place at a personal meeting with the individual candidate where the candidate comes to the company's address for joint signature of the contract of services.
- Where possible and appropriate, the company ensures that the contract of services is drawn up in a language which the candidate understands and that the candidate understands all the details in the contract.
- In special circumstances, the company may consider using independent interpreters to communicate with foreign candidates who do not speak sufficient English to fully understand the terms of engagement.
- The company ensures that the candidate brings the following original documents to the interview:
- Criminal record and consent form (where appropriate)
- Proof of eligibility to work in the UK
- The Company will then check their authenticity and contact the police in case of doubt. The Company will check the date and the date of expiry for all documents/permits.
- The company ensures that the person who is present is identical to the person in the identification documents. The Company will check the photo identification, age, height, eye colour, ear shape etc.
- The company copies all engagement documents and keeps them in the locked filing system at the company's trading address.
The Company has specific declarations contained within a Modern Day Slavery Handout Form which must be signed by the candidate regarding the candidate's rights and obligations.
The following questions are asked at the hiring interview at the company:
- Where did the person hear about the job?
- Did the person pay a third party to come to the UK?
- Has the person or must he/she pay a third party to be employed? Is the person in debt as a result?
- Where does the person live (address)? What is the person's phone number and who should be contacted in case of an emergency?
- The candidate is informed of rights such as hourly rate, working hours and payment details.
Due Diligence
The Company is committed to identifying (as far as is reasonably possible) areas of concern when working with candidates and consider the following to be examples where there may be evidence of forced labour or human trafficking:
- A group of foreigners are presented to the employer by a person (often of the same nationality and/or ethnicity as the foreigners) with good English skills, claiming to be, for example, a friend or family member or just someone who wants to help. The person speaks on behalf of the persons in the group and waits while these persons are at the hiring interview.
- Registration documents or CVs submitted to the company are filled in at a higher level of English than mastered by the candidate.
- The registration documents or CVs are delivered by a 'friend' or 'family member' on behalf of the candidate.
- The candidates seem nervous or secretive and/or act as if they have received instructions from a third party.
- A third party calls the company to talk about a friend or a family member who would like to register with the company.
- When comparing the candidates' phone numbers, it becomes evident that several of them have stated the same phone number.
- When comparing the candidate's addresses, it becomes evident that several of them have stated the same address.
- When comparing the candidates bank details, it becomes evident that several of them have stated the same account information.
- When comparing the person stated by the candidate as the person to be contacted in an emergency, it becomes evident that several of them have stated the same person independently.