Modern Slavery Act Statement
Spencer & Trent Recruitment recognises the importance of preventing modern slavery and human trafficking within our business and supply chains. We are dedicated to taking all necessary steps to eliminate these practices from our operations. With modern slavery still a concern across the UK, the Modern Slavery Act 2015, provides a legal framework to address the criminal acts of slavery, human trafficking, and forced labour.
Modern slavery takes many forms. Under the Modern Slavery Act 2015, it includes:
- Slavery – where ownership is exercised over a person
- Servitude – involving an obligation to provide services imposed by coercion
- Forced or compulsory labour – where work is extracted from someone under threat or penalty and is not undertaken voluntarily
- Human trafficking – arranging or facilitating the movement of someone for exploitation.
Spencer & Trent Recruitment is committed to conducting business ethically and with integrity, upholding all legal requirements to prevent and combat modern slavery.
Structure and Business
Spencer & Trent Recruitment operates as a recruitment agency, placing professionals across various sectors in the UK.
Policy Statement
We commit to transparent, fair, and ethical business practices, aligned with the Modern Slavery Act 2015, ensuring adherence to laws regarding modern slavery both within the UK and, where relevant, internationally.
Due Diligence
Spencer & Trent Recruitment conducts rigorous compliance checks on all candidates during registration and vetting to ensure their identity, right to work, and adherence to legal standards. Whistle-blowing channels are available to all staff and candidates for confidential reporting.
Employee Responsibilities
As an employee of Spencer & Trent, you must ensure that you read, understand, and comply with the information contained within this statement, and with any training or other anti-slavery information you are given.
All employees and those under our control are equally responsible for the prevention, detection, and reporting of slavery and other forms of modern slavery. They are required to avoid any activities that could lead to, or imply, a breach of this anti-slavery policy.
If you have reason to believe or suspect that an instance of modern slavery has occurred or will occur in the future that breaches this policy, you must notify your line manager.
If any employee breaches this policy, they will not only face disciplinary action, and dismissal for gross misconduct but also report it to legal authorities. Spencer & Trent has the right to terminate a contractual relationship with an employee if they breach this anti-slavery policy.
Raising a Concern
Employees should report suspicions regarding modern slavery at Spencer & Trent or within its supply chains. Guidance is available from line managers or the Managing Consultant for clarification.
Protection
Employees raising genuine concerns in good faith will be supported and protected from any retaliatory treatment, even if the investigation finds that they were mistaken. If anyone believes they have faced detrimental treatment as a result, they should inform the Managing Consultant immediately.
Training and Communication
Spencer & Trent Recruitment includes anti-slavery training in the induction process for new employees and communicates its zero-tolerance stance to all partners and suppliers. Ongoing training is available as necessary.
Record Keeping
Spencer & Trent will keep detailed and accurate records of employees and candidates (in line with the Data Protection policy and procedure) and will have appropriate internal controls in place to support this policy.
Monitoring and Review
The Managing Consultant is responsible for annual reviews of this policy to ensure its effectiveness and will implement improvements as needed. Employee feedback is encouraged and welcomed.
This policy may be updated periodically to enhance its effectiveness in combatting modern slavery.
Statement published on 30 September 2024
