Modern Slavery

INTRODUCTION FROM THE CEO

We are proud of the steps we have taken to combat slavery and human trafficking and are committed to acting in an ethical manner with our moral obligation at the forefront of our actions.

We regularly review and improve our practices to combat the atrocities of modern slavery and are keen to work with our recruitment agency partners, end user clients and staff to eradicate this practice in the United Kingdom. It is essential that our suppliers understand and appreciate the standards of business conduct that are expected of any company that we do business with and we only seek to engage with reputable organisations.

ORGANISATION'S STRUCTURE

Our businesses provide temporary labour solutions in various sectors within the UK labour market. We have our head office in Warrington. Our Businesses have over 4,000 employees in the UK and operates primarily in the United Kingdom, with some overseas travel being undertaken by our employees as and when required.

OUR BUSINESSES

• Brookson Solutions Limited – an umbrella business supplying labour to various industries and sectors in the UK via recruitment businesses.
• Brookson CIS Solutions Limited - an umbrella business supplying labour to various industries requiring Construction Industry Scheme registration in the UK via recruitment businesses.
• Brookson Construction Limited – a payroll and back office solution for sole traders providing services into industries requiring Construction Industry Scheme registration in the UK via recruitment businesses.
• Plus Us Medical Care Services Limited – a provider of locum medical services to the healthcare sector, employing medical professionals

OUR SUPPLY CHAINS

Our supply chains include the below who operate and specialise in various sectors within the UK and have a requirement for skilled labour, services and/or personnel:

• Recruitment Businesses
• End-Hirers in the public and private sector
• Temporary workers either working as sole traders or employed by one of our businesses 

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING

Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere within our business or supply chains.

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

As part of our initiative to identify and mitigate risk, we have taken the commercial decision not to become engaged in the supply of unskilled manual labour to agricultural, seafood or manufacturing businesses. We have processes in place to identify and ensure that we do not engage workers within these areas.

We undergo a ‘Ways of Working’ consultation with everyone we engage to ensure the worker is comfortable operating in such a manner. As part of our process, we ensure that no one is under undue influence from any third parties to provide services and ensure that individuals are entering into contracts under their own freewill.

We undertake ‘Right to Work Checks’ and maintain a heightened ‘Know Your Client’ process for all overseas nationals looking to secure work in the UK without discriminating against any workers on the basis of their race, nationality, caste, creed or colour.

We have in place processes and systems to:

• Identify and assess potential risk areas in our supply chains with the use of an escalation process through our Compliance Team.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risk areas in our supply chains.
• Report potential instances of modern slavery and human trafficking.
• Protect whistle blowers.

SUPPLIER ADHERENCE TO OUR ETHICS

We have zero tolerance to slavery and human trafficking and we are keen to ensure that all those in our supply chain comply with our ethics.

We have a dedicated Compliance Team, which consists of senior personnel from legal and accountancy businesses within the Group and this team will field any queries or comments from suppliers, customers, employees or regulators in relation to our approach to combatting slavery and human trafficking.

TRAINING

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 ongoing training to our staff. Training is also provided to all new employees to ensure they are aware of our stance on preventing slavery and human trafficking within the businesses and supply chains and how to identify if someone is being trafficked.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 30 September 2019.