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Modern Slavery Act 2021

Introduction

This statement sets out ReProxy ’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.

As participants in the recruitment industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Our organisation is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

In recent years ReProxy has built an excellent reputation as a market leader for recruiting and supplying skilled specialist candidates throughout the UK. At ReProxy we aim to grow and diversify the markets we serve by recruiting and retaining the best people, empowering them with skills and innovative technology solutions.

Our aim is to be the first-choice partner for hospitality, catering, health and social care professionals and providers, across the globe. Our solutions are delivered through three segments: professional services, specialised staffing, workforce management solutions, and health and social care services.

In line with the ReProxy values of Putting People First, Driven by Excellence, and Always by Your Side, as well as being a leading partner in the recruitment industry, we recognise that we have a strong responsibility to take a robust approach to slavery and human trafficking. We will not tolerate slavery and human trafficking in our business or supply chain. 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 that any form of slavery is not taking place in our own business or supply chains. Whilst we assess the risk of modern slavery as low in our supply chain, we have taken appropriate steps to ensure our procedures are appropriate by:

  1. Ensuring robust recruitment procedures which include immigration checks.
  2. Ensuring employees and Temporary Workers have the correct rights to work status and documents to prove the same.
  3. Confirming that appropriate clearing is obtained through the right agency partners (e.g., DBS, Basic Disclosures) when it’s appropriate to do so.
  4. Ensuring employees and Temporary Workers are appropriately trained
  5. Ensuring strong policies and procedures for the business overall is in place

Our business and livelihood depend upon our customers. Every employee is responsible for ensuring that any contact with our customers and the public at large reflects professionalism, efficiency, and honesty. We constantly strive to provide a ‘Best Value’ high-quality service:

  1. We shall uphold the values of honesty, partnership, and fairness in our relationships with stakeholders.
  2. We shall ensure a high level of business performance while minimising and effectively managing risk.
  3. We shall strive to provide continuous improvement in terms of service quality and cost.
  4. We will register and resolve customer complaints in accordance with our standards of service.
  5. We will deal fairly with temporary workers and suppliers in our supply chain.
  6. We will not create barriers to the use of small and medium-sized enterprises who are qualified to provide goods or services, and we will encourage innovation in our supply chains to increase the value or quality of supply.
  7. We will be fair and reasonable in our payment practices.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

  1. Policies: The CEO and HR Director are responsible for the policy management, control and administration of the policy development process which includes maintaining a central register of all policies, ensuring policies are reviewed in a timely manner, ensuring consistency through the policy development process, archiving superseded policies in the ReProxy repository and removing superseded policies.
  2. Investigations/due diligence: ReProxy adopts a transparent approach to the recruitment and placement of our candidates and employees, and fully complies with the Duty of Candour principles, and the Modern Slavery Act 2020 to 2021. ReProxy has robust contracts and/or service level agreements with all supply chains which promote transparency between both parties. Any incidents of Modern Slavery and/or Human Trafficking are documented, investigated (if appropriate) and referred appropriately to the regulatory bodies in accordance with the ReProxy Incidents Policy/Procedure and in line with the Modern Slavery Act 2015.
  3. Whistleblowing: ReProxy has an independent whistleblowing hotline that employees can access if they suspect modern slavery is taking place.
  4. Training: All ReProxy employees complete a Modern Slavery training module at the start of their employment. Refresher training will be applicable for all ReProxy employees regularly thereafter.

Relevant policies

Modern slavery, Human Trafficking, and other forms of exploitation are included in the ReProxy Safeguarding Adults and ReProxy Safeguarding Vulnerable Children Policies. These policies include warning signs and reporting/escalation processes. Other policies and procedures that further support the identification and management of Modern Slavery and Human Trafficking are:

  1. Whistleblowing for Internal Employees Policy
  2. Whistleblowing for Associate Workers and External Partners Policy
  3. Equality, Diversity and Human Rights Policy
  4. Corporate Responsibility Policy
  5. Complaints Policy
  6. Safeguarding Children Policy
  7. Safeguarding Vulnerable Adults Policy
  8. Recruitment and Selection Policy

Performance indicators

We have reviewed our Quality Performance Indicators (QPIs). As a result, we are:

  • Continuing to review our policies and procedures to ensure that any form of slavery is not happening in our own business or supply chains.
  • Ensuring robust recruitment procedures which include immigration checks are in place.
  • Ensuring employees and Temporary Workers have the correct right to work status and documents
  • Confirming that appropriate clearing is obtained when it is appropriate to do so.
  • Ensuring employees and Temporary Workers are appropriately trained.
  • Requiring all ReProxy employees to complete modern slavery training.

Tim Egbuson

Managing Director

March 2022