Antislavery and Ethical Trading Policy.
Covered within this policy:
- Introduction to JHR’s policy JHR’s organisational structure JHR’s supply chains
- Policy on slavery and human trafficking
- Whistleblowing procedure
- Ethical Trading
- Due diligence process
- Training, monitoring and review of policy and procedures
Introduction
Jo Holdsworth Recruitment Ltd. recognises that all businesses have an obligation to prevent slavery and human trafficking and will do all in its power to prevent slavery and human trafficking within its business and within the supply chains through which it operates.
In 2015, The UK Modern Slavery Act came into effect. In large corporations, modern slavery could be present in supply chains without the knowledge of the company. In a bid to help eradicate modern slavery forever within our businesses and within our clientele’s businesses; We now have strict processes in place, as well as due diligence procedures. In order to ensure all our staff feel comfortable raising any concerns they have (whistleblowing) regarding slavery and/or human trafficking in relation to past, present or future workers, colleagues or prospective candidates, we have designated staff members who are trained on being able to identify potential victims, handle concerns raised in confidence and who are able to escalate further to the necessary authorities.
Jo Holdsworth Recruitment Ltd. recognises that modern slavery can take many forms including but not limited to;
• The trafficking of people
• Forced labour
• Servitude
• Slavery
As one of West Yorkshires leading recruitment experts, we take our responsibility for supplying staff extremely seriously and are aware of the potential for being targeted by traffickers and unlicensed gang masters. Our own processes around candidate engagement ensure our employees are alert to the signs of exploitation, in order to ensure we may take the necessary action(s) promptly and effectively should it be identified.
This statement focuses solely on Jo Holdsworth Recruitment Ltd.’s compliance in line with the Modern Slavery Act (2015) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within our organisation or our clientele’s.
Jo Holdsworth Recruitment’s structure
JHR are a leading supplier within West Yorkshire who are accredited and annually audited by the Recruitment Employment Confederation (REC), employing between 10-50 people in 1 Head Office situated in Angels Wing III, Leeds, LS10 1AF.
Our business consists of recruitment across Office Personnel which includes but is not limited to the following specialisms;
Accountancy & Finance Financial Services
Information Technology Human Resources
Sales & Marketing Legal Services
Contact Centres Executive
Telecoms Office support and professionals
Our Supply Chains
Jo Holdsworth Recruitment Ltd.’s supply chains include, but are not limited to, sourcing and identifying suitable candidates for our clients in line with provided briefs. We expect our clients to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner, promoting similar standards within their own supply chain.
**Jo Holdsworth Recruitment’s policy on slavery and human trafficking
**Workers should be free to choose to work, and free to choose their place of work as well as leave their place of work and/or employer upon reasonable notice.
All workers must be provided with a clear contract of employment.
All workers must be treated in a fair and equal manner and with dignity and respect
Any forms of discrimination, victimization or harassment on the grounds of marital or civil partnership status, sex, sexual orientation, race, ethic/national origin, nationality, disability, religious or political beliefs, age, trade union activity and having or not having dependents are strictly prohibited.
All applicable laws and industry standards on employee wages, benefits, working hours and minimum age will be adhered to. Any young persons under the age of 18 will not be permitted to work at night or in a potentially hazardous environment, and their employment should not negatively affect the young person’s education, health or physical, mental, moral or social development. No young persons under the age of 16 will be employed.
We are committed to ensuring that there is no modern slavery or human trafficking in our organisation or that or our clients.
Jo Holdsworth Recruitment take reasonable steps to ensure prevention of exposing a person to an environment where they could fall victim to slavery and human trafficking through complex one on one interviewing as well as onsite assessments of every client we engage with contractually.
**JHR’s whistleblowing procedure
**If you are concerned about any form of malpractice covered by this policy, you should first raise the issue with Becki Hume, Partner or Jo Holdsworth, Managing Director at JHR or if unavailable another Director.
At the point a concern has been raised, JHR will record that concern and all records are maintained by the Operations Director.
The Director(s) will then decide how to respond in a responsible and appropriate manner under this policy. This will usually involve making internal enquiries and investigations first which may include but are not limited to:
• Complex one on one interviewing with the suspected victim by a staff member of JHR which will include; the assessment of physical appearance to identify signs of malnourishment, unkempt or withdrawnness; Personal effects; Isolated and/or anxious behaviour; Reluctancy to seek help
• Assessment of pay to ensure wages are being paid into the correct workers bank account to the best of our knowledge
• Acknowledgement of any persistent accompany i.e. alleged partners, translators, drivers etc.
When JHR makes an external disclosure, namely to 3rd party authorities such as Police, Immigration, the Tax Office and any supply chains involved with the worker at the time, we are aware of our obligation to keep the affairs of a worker in question confidential unless:
• Disclosure is required or permitted by law; or
• The supplier consents
• The escalating contact at JHR should only divulge relevant information regarding a potential breach of The Act to the appropriate 3rd party.
**Ethical trading policy
**Freely chosen Engagement:
1.1 With the way we work at JHR in collaboration with our clients; We ensure that there is no forced or involuntary labour from our workers. Workers are employed under no financial detriment to themselves and have the freedom to leave their employer after reasonable contractual notice has been given.
Freedom of association and the right to collective bargaining:
2.1 Workers have the right to join and/or form trade unions of their own choosing and to bargain collectively.
2.2 Jo Holdsworth Recruitment adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Representatives are not discriminated against and have the rights and access to carry out their representative functions within the workplace.
2.4 Where the right to freedom of association and collective bargaining is under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.
Working conditions:
3.1 Safe and hygienic working environment shall be provided to all Workers, with any specific Health and Safety requirements being specified. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the work place, by ensuring practical steps are taken to minimise the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded health and safety training where applicable depending on the nature of the working environment, although all workers regardless of environment shall receive an onsite health and safety inductions per work place.
3.3 Access to clean toilet facilities and to potable water, and where appropriate, sanitary facilities for food storage shall be provided.
3.4 The company observing the code shall assign responsibility for health and safety to a senior management representative.
Child labour shall not be used:
4.1 There shall be no new recruitment of child labour.
4.2 Children and young persons under the age of 18 shall not be employed at night or in hazardous conditions.
Standard Wages:
5.1 Wages and benefits paid for a standard working week will meet the national Minimum Wage as set by the UK Government.
5.2 All workers shall be provided in writing with understandable information about their assignments and any specific engagement conditions in respect to wages before commencement of each assignment.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.
Working Hours:
6.1 Working hours, excluding overtime, shall be defined by contract.
6.2 All overtime will be voluntary. Overtime should be used responsibly, taking into account the following but not limited to: the extent, frequency and hours worked by individual worker(s) and the workforce as a whole. It shall not be used to replace regular engagement. Overtime shall be paid as stated on assignment details form for each individual site (varying). Were ever possible Jo Holdsworth Recruitment will encourage overtime payment at a premium rate.
6.3 The total hours worked in any seven-day period shall not exceed 60 hours, except where covered by clause 6.4 below.
6.4 Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances and written acceptance of extended working hours has been obtained by both the Hirer and the Worker.
6.5 Workers shall be provided with at least one day off in every seven-day period or, where allowed by national law, two days off in every 14 day period.
Discrimination is not tolerated:
7.1 There is no discrimination in hiring, compensation, providing access to training, promotional opportunities, termination or retirement based on race, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
Harsh or Inhume treatment is not tolerated:
8.1 Physical abuse, physical discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidating behaviour shall be not be tolerated by any involved parties such as the Employment Agency, Worker or Hirer.
**Due diligence process
**Jo Holdsworth Recruitment Ltd ensures strict compliance checks are carried for all workers supplied, including verification of Identity of each worker and their right to work in the UK before assignments are commenced.
All Jo Holdsworth Recruitment employees are trained and have access to dedicated channels through which they may voice concerns via Jo Holdsworth Recruitment’s Directors. Jo Holdsworth Recruitment are committed to protecting employees who disclose malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.
To ensure the protection of all our workers; any staff members at Jo Holdsworth Recruitment who maliciously make a false allegation will be liable to disciplinary action.
**Training, monitoring and review
**All staff within Jo Holdsworth Recruitment are expected to comply with laws and acts in accordance with guidelines and regulations, and act with honesty and integrity in such situations. We are committed to reviewing our policies annually to ensure our colleagues have access to any additional information and support they may require with regards to human trafficking, forced labour, servitude and slavery. Jo Holdsworth Recruitment Ltd. will regularly monitor the effectiveness of this policy to ensure it is working in practice. The Directors will provide information and/or training on any changes that are made.
Summary
Our company has taken and will continue to take all reasonable steps towards promoting fair, inclusive and ethical working environments for all. JHR Ltd conduct annual reviews to ensure all staff are fully training and compliant in adherence to this policy.