Introduction from the Managing Director of Net Temps Limited
Modern Slavery is a criminal offence under the Modern Slavery Act 2015 (“The Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
This document sets out the policy of Net Temps Limited with regards to the aim of preventing modern slavery within its business and supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act.
As a company, we have a zero tolerance to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or our supply chain.
The responsibility to uphold this policy lies with all staff involved in the recruitment, management and supply of workers on a day to day basis.
The Structure and Business of Net Temps Limited
Net Temps Limited is a private limited company, operating as a niche recruitment agency specialising in the supply of temporary, freelance and permanent labour to the construction, engineering and allied industries.
It has 9 bespoke divisions and continues to look at where value can be added for its clients by extending its service provision:
- Power & Utilities Division;
- Construction Trades and Labour Division;
- Management and Professional Division;
- Plant Operatives Division;
- Pre-Cast Concrete Division;
- Mechanical & Electrical Division;
- Crane Division;
- Piling Division; and
- An Industrial, Warehouse and Logistics Division.
STEPS FOR THE PREVENTION OF MODERN SLAVERY
We are committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our obligations under the Act. We expect the same high standards of our business partners and associates.
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk we have put in place the following systems to:
- Identify and assess potential risk areas in our supply chain;
- Mitigate and resolve any identified risk of slavery and human trafficking occurring in our supply chain.
- Monitor potential risk areas in our supply chain; and
- Protect whistle blowers.
This is managed through the relationships between Net Temps Limited’s staff and their business partners and associates.
Supplier Adherence to our Values and Ethics
Net Temps Limited has a long history of working as a sole supplier or under preferred supplier schemes with business partners and associates.
Our supply chain is underpinned by rigorous contractual processes, however at all times Net Temps Limited shall seek to engage with its business partners and associates both to convey to them our Modern Slavery Policy and gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
We shall seek compliance with this policy at all times or any policy on Modern Slavery developed by a business partner or associate that seeks to implement the same level or higher level of standards in respect of Modern Slavery and Human Trafficking.
We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we have audited the present basis upon which we supply temporary and permanent workers to our business partners and associates and will appraise the supply of any worker that is supplied under new conditions of supply.
We have a dedicated compliance support team, which consists of involvement from the following departments:
- Legal, Compliance & HR
- Finance, and Payroll
- Sales and Procurement
Net Temps Adherence to the Values and Ethics relating to the prevention of Modern Slavery
As a Company we shall:
- Commit to embedding a culture where all workers are treated with dignity, respect and with a sense of worth.
- Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
- Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
- Ensure that all staff responsible for directly recruiting workers are aware of issues around third party labour exploitation and signs to look for and have signed appropriate Compliance Principles and are aware of the Red Flag Alerts set out later within this policy.
- Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
- We shall ensure that a situation does not develop whereby total control of workers from particular nationalities is placed in the hands of one consultant of the same nationality. Whilst it is recognised that many native language speakers working for labour providers and users provide invaluable assistance to workers with poor English language skills, there is an increased potential for exploitation and mistreatment when there is a single person acting as a ‘language gateway’ either for the labour user or provider. Accordingly we will always try to provide a second point of contact for these workers and therefore an opportunity to complain about any alleged mistreatment to another person.
- We will not fall into the habit of using an individual worker as a single contact point to organise a group of workers to attend work at any one time.
- Where there is a ‘triangular relationship, between workers, labour intermediaries and end clients we shall make it clear who problems should be raised with, to include where appropriate the provision of our Complaints Policy, which will be operated fairly and in line with natural justice.
- Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Police. Any such reports shall be made to the respective authorities via the Compliance & Operations Manager.
- Provide information on tackling “Hidden Labour Exploitation” to our workforce through a variety of formats such as workplace posters, worker leaflets, induction, other training.
- The company will encourage and support all Net Temps’ Employees and Contractors to report cases of Hidden Labour Exploitation or Human Trafficking; whether they are themselves a victim or know anyone else within their community that may be. We shall keep any information provided confidential within the departments necessary to deal with the matter properly, and shall investigate matters appropriately and with sensitivity.
- We shall always adopt and use recruitment selection criteria in a fair and non-discriminatory way in respect of the recruitment of both Temporary and Permanent Workers.
- We shall agree labour sourcing methods with our clients and require all other organisations in the labour supply chain to adopt policies and procedures consistent with the above.
- All of Net Temps’ employees will be made aware that failure to comply with this policy may result in disciplinary proceedings, up to and including dismissal; being taken in line with the Company Disciplinary Policy
All employees have an obligation to familiarise themselves with our procedures to help in the identification and prevention of modern slavery and to conduct business in such a manner as to prevent the opportunity for and incidence of modern slavery. Adherence to this policy forms part of our staff’s obligations under their contract of employment.
In addition all employees engaged in recruitment activities must:
- Only interview applicants in an approved location.
- Not allow applicants to complete registration documents on behalf of others.
- Not accept money, favours or any gifts at all from applicants or workers.
- Not loan any personal money to temporary workers.
- Notify a manager when informed by an applicant or worker that they have paid money to be introduced to the Company.
- Not allow an unauthorised agent or individual to introduce job applicants to the Company.
- Notify a manager if they suspect that an individual of introducing job applicants to the Company for personal gain.
- Not act as landlords or be in involved in the provision of accommodation, transport or other paid for services to workers.
- Not allow anyone other than an authorised person to choose which workers are selected for work shifts.
- Not force or coerce temporary workers to work against their will.
- Not threaten or subject workers to physical or mental mistreatment.
- They must treat applicants and workers with dignity and respect.
- Raise any knowledge or suspicions of illegal or dubious activities regarding agents, temporary workers or colleagues to a manager immediately. All employees MUST:
- At time of placement for work, confirm that all details for the job, shift times, pay rates and location etc. are given to and understood by the worker, to ensure that the worker has all the relevant information.
- During and after registration, direct communication must be made by the Net Temps’ Representative to the worker and must not be made through any third party (even if it’s a relative or friend).
- All communication must be logged on the Worker’s Profile on VDQ.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also expect our business partners and associates to provide training to their staff and suppliers and providers in their respective supply chain.
RED FLAGS – CHECKLIST OF POTENTIAL INDICATORS OF WORKER EXPLOITATION.
The following is a non-exhaustive list of some of the flags which might indicate that worker exploitation is occurring or may occur:
- The individual with control over workers may seek to befriend Net Temps or frontline staff and offer to find them workers, often at short notice.
- A number of workers are introduced to Net Temps by a particular individual, usually of the same nationality, with good English language skills. This individual may claim he is a friend, relative, uncle, cousin etc, or just helping out but speaks for the other individuals and controls the conversation. S/he waits whilst the individuals are being interviewed.
- Externally completed registration documents are in a significantly better standard of English than the applicant possesses.
- A number of externally completed registration documents are brought in by one individual on behalf of his “friends” or “family”.
- A number of externally completed registration documents are brought in having been completed in the same handwriting.
- Applicants appear frightened, agitated or secretive and act as if they are instructed by another.
- A third party rings in to book a friend or family member as being available for a work shift.
- Workers say they rent from a landlord who works for Net Temps or labour user.
- Registered workers keep turning up to see if work is available and appear to be accompanied by individual(s) who stay in the background.
- Workers are delivered in minibuses or people movers, particularly where such transport is not licensed and/or the driver is not part of the permanent or agency work force.
- One worker supplies food in the workplace for a number of the agency workers.
- Workers physical appearance may show signs of injury and malnourishment and their general appearance may be unkempt with inappropriate clothing.
- A rise in the number of non-English speaking workers of a certain nationality where they are organised by a particular recruitment consultant or labour user supervisor of the same nationality.
- A particular individual may stay close to a group of workers when anyone from authority is present.
- A pattern where migrant workers of the labour providers or labour users workforce stop working suddenly for no particular reason.
- Checking addresses shows high occupancy of particular houses of agency workers.
- Checking addresses shows shared high occupancy of particular houses between permanent and agency workers.
- Checking bank accounts shows a number of unrelated workers paid into one account.
- Checking mobile phone numbers shows a number of unrelated workers contactable through one number.
- Checking emergency contact numbers shows a number of unrelated workers contactable through one number.
- Checking documents for same next of kin and /or same place of origin/location in home country.
In addition if:
- You suspect a person acting on behalf of Net Temps Limited or one of our business partners or associates is seeking to exploit another in a way which could amount to modern slavery;
- You suspect that a person acting on behalf of one of our suppliers is seeking to exploit another in a way which could amount to modern slavery;
- You have received an approach from a person acting on behalf of Net Temps Limited and they have invited you to participate in acts which could result in offences under the Modern Slavery Act 2015 being committed; and
- You have information which leads to the rational conclusion that a person acting on behalf of Net Temps Limited or it’s business partners or associates is preparing to commit, is committing or has committed an act in contravention of the Modern Slavery Act 2015.
You are obliged to report your concerns to a member of the Net Temps’ Management Team.
How to Report Modern Slavery or Human Trafficking
If you have any of the non-exhaustive concerns listed above you may use the following methods of reporting:
Employees may at any time report a concern about suspected modern slavery associated with the Company or our suppliers. Concerns can be raised directly at any time either directly to the Management Team, or they can be raised under the Company’s Whistleblowing Procedure (found in the Company Handbook). The nature of the complaint will determine the Company’s next course of action.
The Company encourages members of the public or people not employed by Net Temps Limited to write in confidence to the Company’s Compliance and Operations Manager to raise any concern, issue or suspicion of modern slavery in any part of our business or related supply chain.
Concerns will be investigated by a member of management and where applicable a Record of Third Party Exploitation will be completed.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business or that of our supply chain partners.
Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.
The company will accept and take seriously concerns communicated anonymously, but it is noted that this does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their name to allegations. However, any employee that is found to have made a claim or allegation that is found to be malicious or vexatious will result in disciplinary action being taken against them.
RESPONSIBIILTY FOR THE POLICY
Ultimate responsibility for the prevention of modern slavery rests with the Company’s Management Team, who has overall responsibility for ensuring this policy and its implementation complies with our legal and ethical obligations.
All divisional managers are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.
COMMUNICATION AND AWARENESS OF THE POLICY
Our zero tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners and associates at the outset of our business relationship with them and reinforced as appropriate thereafter.
This Anti-Slavery Policy will be reviewed annually by the Net Temps’ Management Team and may be amended from time to time.
This Policy is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking Statement.