MODERN DAY SLAVERY ACT
MODERN DAY SLAVERY ACT
At Ben Recruitment, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain.
We have taken concrete steps to tackle modern slavery, as outlined in our statement.
This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020.
Our business and supply chains
• Ben Recruitment is trading style of Recruitment Staffing Solutions LLP, which is a limited liability partnership incorporated in, and under the laws of, England and Wales. The LLP is owned and controlled by its members (who we call partners).
• We operate in the professional services sector out of a single office located in London.
• We provide a broad range of recruitment professional services to a diverse client base which originates within the United Kingdom.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors.
Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.
[We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.]
In the past year, we conducted a risk assessment of our supply chain by taking into account:
• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups
This assessment will determine our response and the risk controls that we implement.
Ben Recruitment operates the following policies for identifying and preventing slavery and human trafficking in our operations:
• Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of the whistle-blowers.
• Code of Conduct - our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
• Purchasing Code - we have updated our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking.
Supplier due diligence
Ben Recruitment conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals.
• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
• They do not use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment
• They do not require employees to post a deposit/bond and do not withhold their salaries for
They do not require employees to surrender their passports or work permits as a condition of employment
Ben Recruitment has raised awareness of modern slavery issues by putting up posters across our facilities and sending an email that is focused specifically on modern slavery to all our staff, which explains:
• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery
In addition to the awareness programme, Ben Recruitment will roll out a fresh e-learning course to all employees and supplier contacts, which covers:
• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
• How employees should respond if they suspect slavery or human trafficking
• How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
• What external help is available for the victims of slavery
• What terms and guidance should be provided to suppliers in relation to slavery policies and controls
• What steps Ben Recruitment will take if a supplier fails to implement anti-slavery policies or controls
• An attestation from employees that they will abide by Ben Recruitment anti-slavery policy
Measuring how we are performing
Ben Recruitment has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain.
• How many employees have completed mandatory training?
• How many suppliers have filled out our ethics questionnaire?
• How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
• How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?
• What are the findings of our cross-functional Human Rights team, which reviews how we are addressing modern slavery and human trafficking?
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 which covers 5th April 2022 to 5th April 2023.
Signed: Harrison Dokubo
Position: Managing Director
For and on behalf of Ben Recruitment Ltd
Date: 5th April 2022
Ben Recruitment is a trading style of Recruitment Staffing Solutions LLP The Aspen Building, Vantage Point Business Village, Mitcheldean, Gloucestershire, England, GL17 0DD
Company number OC352156 Registered office address: 20-22 Wenlock Road, London N1 7GU | Registered number: 10104108 | Ben Recruitment Ltd is registered in England
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