Modern Slavery Statement
Modern Slavery Statement
Hillgate Recruitment Services is committed to promoting and maintaining the highest level of ethical standards for all business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values and prevent Modern Slavery, which encompasses slavery, servitude, human trafficking, and forced labor.
Purpose & Scope
This statement is made under our legal and regulatory obligations according to section 54(1) of the UK’s Modern Slavery Act 2015 (the Act) and sets out the steps we have and continue to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
The company is proud of the group-wide conditions under which employees, temporary workers, and contractors are engaged. Given the nature of our business, our Board and Senior Management teams each consider that there is a minimal risk (approximating to no risk) that, either within the Group or across our limited supply chains that support our business activities, we are in any way involved in or even tangentially supportive of, or complicit in slavery and human trafficking.
The employment and procurement practices operated by the businesses within the Group ensure that the companies within our Group are rightly viewed as excellent and supportive employers. To this extent, our Group companies operate as purchasers of goods and/or services, and therefore we expect a high level of ethical conduct from those businesses with which we conduct business.
Anti-Slavery Policy Statement:
The Company has a zero-tolerance policy towards any form of slavery and human trafficking and is committed to acting ethically, fairly, and with integrity and transparency in all business dealings and relationships, and implementing effective systems and controls to safeguard against any form of slavery or human trafficking from taking place within our organization or that of our supply chain.
This Anti-Slavery Policy Statement is the principal articulation of the Group’s policy on slavery and human trafficking and is intended to inform and influence all company operating procedures.
Group Structure
The company is incorporated in England, with its registered Head Office located in Stockport. All subsidiary companies of the Group are either regulated by the CQC or serve a purpose ancillary to the Group’s principal activities of supporting public and private organizations in providing high-quality recruitment and staffing services by supplying expert professionals across healthcare and non-healthcare sectors, and on both a temporary and permanent basis.
Company Policies
The company operates an accredited ISO Quality Management System, with integrated policies, processes, and procedures for all business activities and operations. As part of this system, several policies are operated to ensure we conduct business ethically and transparently, including but not limited to:
1. Anti-Slavery Policy
2. Recruitment Policy
3. Compliance Policy
4. Whistleblowing Policy
5. Safeguarding Adults & Children Policies
6. Codes of Practice & Behaviors for Management & Employees
7. Anti-Bribery Policy
The Group companies also articulate a series of employee rights and benefits available to employees in the employee handbooks and individual employment contracts for each staff member. Each of the subsidiary operating companies has an Executive Officer or Director who has reviewed and agreed to the terms of this statement. Each of these executives has reporting responsibilities to management and the various boards of companies within the Group.
The Group uses an external auditor and receives regular update reports from both the external auditors and its own internal auditor and finance function. A combination of these procedures and functions operates to help identify, assess, and monitor potential risk areas and mitigate the risk of slavery and human trafficking occurring in our business and supply chains.
In the articulation of this formal Anti-Slavery Policy Statement for the Group, we seek to ensure when entering into material contracts that all those in our supply chain and our contractors comply with our stated Anti-Slavery Policy in particular when seeking service tenders or when auditing our suppliers.
Supply Chains
The company operates a supplier policy, an approved supplier engagement process, and from which a limited preferred/approved supplier list is maintained.
All suppliers are subject to due diligence processes before being approved as suitable for inclusion on our Preferred Supplier Register. These due diligence processes include but are not limited to, online vetting checks to ensure each organization has never been convicted of any offences that relate to or give rise to concerns regarding modern-day slavery.
This anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy. In addition, and as part of our contract with suppliers, authorized signatory confirmation that:
1. They have taken steps to eradicate modern slavery within their business;
2. They hold their suppliers to account over modern slavery;
3. They pay all employees at least the national minimum wage/national living wage (as appropriate, or London Living Wage for London only) currently in operation;
4. We may terminate the contract at any time should any instances of modern slavery come to light.
Due Diligence & Assessing Slavery/Human Trafficking
As part of our initiative and duty of care as an employer, we aim to directly identify actual, or the potential for, human trafficking and/or slavery, using the following and direct methods:
1. Assessing the physical appearance of candidates or current employees/staff at interviews and/or other arranged meetings/appointments; whilst maintaining an awareness of the signs of psychological abuse (i.e. malnourishment, unkemptness, those that appear withdrawn/fearful or who wear the same clothes daily);
2. Record details of persons who attend the office accompanied by others, i.e. those who don’t or are unable to travel alone, appear under the influence of others, fail to interact or appear fearful, those reluctant to discuss current circumstances/arrangements/available working patterns, or who are unfamiliar with the local area/region;
3. Record details of persons who do not have, or have difficulty in producing, their own personal identification and/or other documents/records, or have to seek these from other persons;
4. Monitor registered addresses of personnel using E-Systems to ensure employees/staff who have not declared themselves as family or marital/civil or other partners, are not residing at the same address unless a reasonable justification exists;
5. Record details of persons who upon being offered temporary/permanent work positions firstly seek agreement from family/partners/other persons before acceptance, or similarly whose family/partners liaise with the company on behalf of the person;
6. Operate a policy whereby all employees/staff must arrange and discuss their employment/work/assignments/patterns/availability etc. directly with the company themselves, and not through a third party, unless a suitable justification exists.
Training
Our policy and processes for the prevention of slavery and human trafficking will be communicated to all employees, temporary workers, and contractors to ensure a high level of understanding of the risks of modern slavery and human trafficking, and will further form part of the company’s training and supporting materials.
Responsibility & Review
This policy is endorsed and regulated by the Group CEO and has the full support of the Statutory and Managing Board of Directors, and Management team. The effectiveness of this policy and strategy shall be monitored on an annual basis or as and when changes to legislation are made to ensure fairness and suitability. The responsibility for ensuring compliance with this policy lies with the company’s Senior Management Team.
Policy Approval:
Name: Joe Itua
Position: Development Director
Sign Name: 
Reviewed: 01 / 11 / 2023