Modern Slavery Policy

Company Name:	The RecPool Group LTD (“the Company”)
Model Policy No.	IF03.CPP.01 “IF03”
Model Policy Name:	Modern Slavery Policy
Date:	01/10/2017

Our Policy

1. The RecPool Group is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
2. The RecPool Group is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
3. The RecPool Group provides appropriate training and awareness information for all of its staff.
   In particular:
   • All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
4. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to their Divisional Manager.
5. Reports surrounding these issues are taken extremely seriously by the senior management team who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
   • Working with the appropriate organisations to improve standards,
   • Removing that organisation from our preferred supplier list,
   • Passing details to appropriate law enforcement bodies.
6. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
   • The amount of time spent on audits, re-audits, spot checks, and related due diligence,
   • The level of modern slavery training and awareness amongst our staff.
7. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

This policy was adopted on 01/06/2018 and is reviewed annually.

Modern Slavery Statement

This statement is made as part of the RecPool Group’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how the RecPool Group operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff. 

This statement is published in accordance with section 54 of the Act and relates to the financial year June 2018 to June 2019. It was approved by the Management on 1^st June 2018 by Mike Murdoch.

1. Our Business

The RecPool Group is a limited company operating in the recruitment sector. We provide introduction services and supply temporary workers in the Public and Private sectors.

The RecPool Group is an independent business. 

1.1 Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.

The hiring companies that we work with are located nationally. The work-seekers / workers we supply live nationwide (within the UK).

1.2 Other relationships

As part of our business, we also work with the following organisations:

• The Recruitment and Employment Confederation (rec.uk.com)

2. Our Policies

The RecPool Group has a modern slavery policy.

In addition, The RecPool Group has the following policies which incorporate ethical standards for our staff and our suppliers.

• IF01: Equal Opportunities
• IF02: Complaints Policy and Procedure

2.1 Policy development and review

The RecPool Group’s policies are established by our senior leadership team, based on advice from HR professionals, industry best practice and legal advice, and in consultation with The Recruitment and Employment Confederation. We review our policies annually, or as needed to adapt to changes.

3. Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

• When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
• We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.
• We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems. 

Additionally, we have taken the following steps to minimise the possibility of any problems:

• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.

Our staff are encouraged to bring any concerns they have to the attention of management.

4. Our Performance

As part of monitoring the performance of The RecPool Group we track the following general key performance indicators:

• The level of training and awareness amongst all staff
• The level of compliance and transparency within our supply chain
• The Speed of which related complaints are investigated

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our senior leadership team:

• The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
• The percentage of candidates supplied from our preferred supplier list
• The level of modern slavery training and awareness amongst our staff

We carefully consider our indicators, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

5. Our Training

All of our staff receive training and support that is appropriate to their role. In particular:

• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this, our staff are encouraged to discuss any concerns that they have

Training is refreshed annually.