Table of Contents

Modern Slavery

Modern Slavery Policy

1. The Importance of Addressing Modern Slavery

Modern slavery represents a severe crime and a profound violation of basic human rights. It encompasses practices such as forced labour, human trafficking, servitude, and slavery—all forms of exploitation where an individual’s freedom is curtailed for economic or personal benefit. Smart Staff Connect upholds a strict zero-tolerance stance on modern slavery. We commit to ethical conduct, operational integrity, and implementing stringent measures to eliminate any occurrence of modern slavery within our organisation or supply chain.

Upholding transparency is a cornerstone of our efforts to combat modern slavery, aligning with our duties under the Modern Slavery Act 2015. We demand the same high ethical standards from our contractors and business partners.

2. Purpose and Scope of This Policy

This document serves as a consolidated reference for modern slavery training and outlines the expectations we hold for all team members, suppliers, and partners in preventing exploitation. Compliance with this policy and the Modern Slavery Act is mandatory for all employees and associates. Understanding and adherence are essential for fostering a workplace free of exploitation.

3. Duties and Obligations

Commitment to Human Rights

All team members are expected to treat clients and partners with dignity, fairness, and respect. For those interfacing with clients or suppliers, it is imperative to uphold the following human rights standards:

  • Universal Declaration of Human Rights by the United Nations
  • Declaration on Fundamental Principles and Rights at Work by the International Labour Organisation
  • UN Principles on Business and Human Rights
  • UN Global Compact Principles
  • Ethical Trading Initiative Base Code

Proactively identifying and addressing modern slavery is vital to our mission. If you identify potential indicators of exploitation, it is your duty to report them promptly using the outlined channels.

Education and Awareness

Serious concerns about unlawful activities, breaches of this policy, or unethical behaviour must be reported. Use the whistleblowing framework for significant issues, while minor concerns should be discussed with a Manager.

If direct communication is not an option, escalate concerns through these avenues:

  • Engage with your Manager

Recognising Signs of Modern Slavery

Identifying modern slavery requires vigilance. Common indicators include:

  • Withdrawn or fearful demeanour, isolation from others
  • Signs of malnutrition, injuries, or poor health
  • Lack of personal possessions or identity documents
  • Dependency on a controlling individual for communication
  • Restricted access to personal finances or bank accounts

Oversight of Supply Chains

Exploitation can manifest within various areas of business operations. Risk-prone sectors include:

  • Recruitment agencies and labour providers
  • Service sectors like catering, cleaning, and security
  • Construction and site maintenance suppliers
  • Gig-economy delivery services

Maintain awareness and act responsibly to mitigate risks within these categories.

Reporting Suspicions of Modern Slavery

It is crucial to avoid direct engagement or investigation if modern slavery is suspected. Instead:

  • Discreetly notify your supervisor of any concerns
  • Ensure your supervisor contacts Smart Staff Connect’s Legal Team to inform appropriate authorities
  • Additionally, report concerns to the Modern Slavery Helpline at 0800 0121 700 or through modernslaveryhelpline.org/report

Safeguarding Through Whistleblowing

We encourage openness in reporting suspected modern slavery, breaches of policy, or other unethical practices. If speaking to a supervisor is unfeasible, contact HR, the Legal Department, or Internal Audit. The confidential Reporting Line remains an available alternative.

4. Supporting Policies and Documents

This policy is complemented by:

  • Anti-Bribery and Corruption Policy
  • Business Conduct Code
  • Whistleblowing Procedures

5. Contact Information

For inquiries or further assistance, reach out to Smart Staff Connect at info@smartstaffconnect.com