This statement is a placeholder template. It must be completed, reviewed by a qualified legal adviser and approved by a director before publication. Items in square brackets must be confirmed.
Introduction
This statement sets out the steps Netox Ltd has taken to prevent modern slavery and human trafficking in its business and supply chains for the financial year ending [FINANCIAL YEAR END].
Section 54 of the Modern Slavery Act 2015 requires commercial organisations with an annual turnover of £36 million or more to publish a statement each year. Netox Ltd is below this threshold. We publish this statement voluntarily because we believe transparency matters, particularly in recruitment.
Our business
Netox Ltd is a London-based consultancy providing programme and change delivery, recruitment, and HR, procurement and bid services. We recruit in the United Kingdom, Germany, Sweden, the Netherlands and Japan.
[Add a short description of organisational structure and headcount.]
Our supply chains
Our main suppliers include [technology and software providers, office services, professional advisers, umbrella and payroll companies, and job boards, to be confirmed]. As a recruitment business, we also supply workers to clients, which means we must consider how those workers are engaged and paid.
Our policies
We have adopted the following policies, which support our approach to preventing modern slavery:
- [Modern slavery and ethical recruitment policy]
- [Whistleblowing policy]
- [Supplier code of conduct]
- [Equality, diversity and inclusion policy]
Due diligence and risk assessment
We consider that the highest areas of risk in our business relate to the supply of temporary and contract workers, and the use of third-party payroll providers. To reduce this risk, we [describe measures, for example]:
- Carry out right-to-work and identity checks on all candidates we place.
- Never charge candidates fees for finding them work, in line with the Conduct of Employment Agencies and Employment Businesses Regulations 2003.
- Pay temporary workers directly or through approved payroll providers that we have reviewed.
- Watch for indicators such as shared bank accounts, third parties controlling a worker’s documents, or a worker being unable to speak for themselves.
Training
[Describe training provided to staff, particularly consultants who recruit and place workers.]
Measuring effectiveness
We will assess the effectiveness of our approach using [key performance indicators to be confirmed, for example completion of training and supplier reviews].
Approval
This statement was approved by the board of Netox Ltd on [DATE].
[Name] [Director] Netox Ltd [Date]