Modern Slavery and Human Trafficking Statement 2020-2021
The Staffing Group Ltd recognises the vital importance of tackling Modern Slavery and human trafficking (slavery, servitude, forced labour and human trafficking). The Staffing Group Ltd acts to achieve the highest ethical standards and to prevent and identify Modern Slavery and human trafficking within its businesses and supply chains.
We are committed to working with our suppliers to ensure they have appropriate ethical and responsible policies and processes in place and support them in closing any areas of risk these checks may identify.
About our Business
The Staffing Group Ltd is a labour provider and operates from over 113 group locations across the UK and are one of the top 4 largest suppliers of contractual labour pay rolling at peak, in excess of 25,000 temporary colleagues. The Staffing Group Ltd is made up of a number of related business:
Single Resource Ltd is an on-site managed service recruitment business, providing large scale volume temporary recruitment solutions within the warehouse, distribution and food manufacturing industries. Operating from 79 locations across the UK, they are one of the top 4 largest privately owned suppliers of contract labour and regularly payroll in excess of 15,000 temporary colleagues per week.
Extra Personnel Ltd is a specialist provider of industrial, transport, commercial, automotive and skilled & technical recruitment operating from 34 UK locations and includes the following trading subsidiaries:
ep professional recruits within 10 specific candidate sectors and offer temporary, permanent, interim and contract solutions across the UK. With a team of specialist consultants and expert resourcers working from our midlands hub, they use the latest technology in terms of candidate attraction. Specialisms include sales & marketing, HR, logistics, procurement, supply chain, finance and technical & engineering.
Extra Drivers is our specialist driving division and are a recruitment process outsourcing (RPO) company specialising in managed service provision on a nationwide basis. Extra Drivers provides a bespoke service for the supply of volume transport labour.
Extra Aviation is a specialised division with its own management structure which focuses on the intricacies of recruiting into the ever changing world of Aviation. We have a wealth of knowledge spread across the teams which allows us to work with our Labour Users to ensure all due diligence is followed to ensure the right candidate for the industry.
Extra Personnel Automotive Ltd provide onsite managed services, remote and branch lead recruitment models for multiple site locations across the UK within the automotive sector.
The Staffing Group’s financial year ended on 31 May 2020.
As a group we are committed to working alongside any organisation which will support in the overall aim of reducing Modern Slavery within our supply chain and across the UK.
Exposure of Modern Slavery
We know that as a large supplier of labour, particularly to the food sector, multiple Modern Slavery risk factors may be present in our own operations and our supply chain and these may not be obviously apparent.
We also recognise that factors such as the current pandemic can affect those who are vulnerable and they may be at greater risk of falling victim to Modern Slavery and human trafficking.
As an ETI (Ethical Trading Initiative) member we adhere to the Base Code to ensure employment is freely chosen. We have identified our salient risks and set out our commitment to tackle and prevent these risks in our Forced Labour and Ethical Policy.
Policies and Procedures
Our Preventing Hidden Labour Exploitation Policy and a Forced Labour and Ethical Policy sets out the responsibilities of each individual within the business to identify and report any suspicions of potential cases of exploitation.
Our Responsible Sourcing and Supply Policy has been developed for the responsible sourcing and supply of workers which, complies with national laws, global standards, and the ethical codes of our labour user clients which further sets out specific protections and access to remedy for all workers.
Our Standard Operating Procedures imbed our practice that all those in our operations and supply chains, remain vigilant during the entire on boarding and recruitment process to identify indicators (“Alert Flags”) of Modern Slavery and if any such concerns are present to handle these sensitively and professionally.
Collaborative meetings and processes are developed and implemented alongside our Labour Users to strengthen our ability to identify and prevent potential cases of Modern Slavery. As a member of Sedex (Supplier Ethical Data Exchange) we invite our clients to view data we hold on our ethical and responsible business practices.
Policies and procedures are developed and reviewed regularly to incorporate our findings from investigations by our trained Compliance Department alongside the relevant subject matter expert, and signed off at Director level.
In 2020 we revised a number of policies including our whistleblowing policy which sets out the Company’s commitment to high standards of ethical, moral and legal business conduct. In line with that commitment we encourage those who have serious concerns about any aspect of the organisations work to come forward and voice those concerns without fear of detriment.
We require all 2nd tier labour suppliers to adhere to applicable national laws and standards in relation to labour practices and human rights, including the Modern Slavery Act 2015 and have the appropriate policies in place.
In 2019 along with other likeminded recruitment businesses a new group was formed titled the Compliance Intelligence Network (CIN); the aim of this group is to work together to combat Modern Slavery, share best practice and share information and intelligence on a local level.
In 2020 we strengthened our recruitment processes and training of labour exploitation to take account of the conditions the pandemic imposed on the recruitment process and the risks that may be open to vulnerable individuals who may be at greater risk of labour exploitation.
Due Diligence Processes
We understand that our biggest exposure to Modern Slavery is within the recruitment process and so due diligence is expected from the first point of contact with our candidates and to be a constant presence through the employment relationship. These include:
Welfare Intelligence – All workers are invited to complete a welfare questionnaire via our online portal when they register with us. This highlights any Alert Flags and further welfare meetings are held where required.
Reporting on Intelligence – we report weekly on houses of multiply occupancy, dual bank accounts and mobile numbers to monitor potential indicators across our group. All concerns are investigated and we liaise with local councils to investigate all accommodation Alert Flags further.
Robust auditing – Our auditing process is in place to ensure all of our operations and partners in our supply chain adhere to our standards and comply with the relevant legislation / regulations and are, amongst other things, intended to identify any Modern Slavery practices or areas of potential risk to the supply chain.
2nd Tier Labour Providers – All 2nd tier labour providers are subjected to a due diligence audit prior to supply, and then, an annual audit. This is to ensure they hold a GLAA licence and meet our required standards of supply, including, how they are applying and adhering to the applicable national laws and standards, their human rights policy and procedures, as well as labour practices and HSE. The output of these assessments are assessed by the Quality and Compliance Department to monitor for areas of potential risk.
If a supplier’s practices are found to be unsatisfactory or non-conformant, we will arrange a full audit inspection and address the outcome on a case by case basis, seeking external advice where appropriate.
Training and Awareness
We recognise that knowledge is key and all employees must complete our mandatory Modern Slavery training upon commencement of their employment and commit to preventing labour exploitation by agreeing to our “Recruiter Compliance Principles”.
Bespoke training is given to those locations identified at higher risk, using previous cases and investigations as training material.
Newsletters highlighting recent Modern Slavery suspicions in the community and how we have tackled Modern Slavery, along with posters are routinely published across the business to reinforce our commitment to tackling Modern Slavery.
In 2020 we strengthened our training and held webinars for all of our employees to share our findings through intelligence and investigations so all employees can proficiently care and manage any indicators or any acts of potential Modern Slavery.
In 2020 we rolled out new training material to accompany our current training videos to raise further awareness amongst our temporary workforce.
In 2021 we aim to launch our new Flexi-Worker training platform. This will provide our temporary employees with a platform to carry out up to date e-learning and understand the risks they may be exposed to in relation to Modern Slavery and how to report any concerns they have without any recourse or detriment.
The attendance of roadshows, webinars and workshops provided by external companies such as the Association of Labour Providers, Stronger Together and the Gangmaster Labour and Abuse Authority is promoted to all relevant staff and top level management in order to maintain knowledge and distribute across the business.
We offer key members of the business the opportunity to undertake a Certificate in Professional Development for Investigating Modern Slavery. This course has been developed by the GLAA in conjunction with Derby University and provides guidance on how to conduct an investigation effectively whilst protecting potential victims.
Single Resource remains as a business partner of Bright Future. Bright Future is an initiative created by the Co-op to offer paid work placements leading to a non-competitive job interview for survivors of Modern Slavery. We will continue to partner with our participating Labour Users to launch and raise greater awareness of Bright Future through 2021.
The Staffing Group commits to ensuring we operate towards the best practices at all times. Evidence of this can be seen through the Stronger Together website, which shows we have taken the relevant steps to become a Business Partner of Stronger Together since 2015.
By continually assessing the risks of any form of Modern Slavery taking place within our operations and implementing processes and polices to try to minimise these risks, we are able to support the relevant Government authorities in reporting any identified situations, and as such protect our business, our Labour Users businesses and first and foremost, our Flexi-Workers.
This statement has been made in accordance with the reporting requirements of Clause 54, Part 6 of the UK Modern Slavery Act for the year ending 31 December 2021.
This statement was approved by:
Group Managing Director
18 November 2020