Modern slavery policy
INTRODUCTION FROM THE CEO
We are committed to acting in an ethical manner and are aware of our moral obligation to assist in eradicating modern slavery and human trafficking.
We regularly review and improve our practices to combat slavery and human trafficking and are keen to work with our recruitment agency partners, consulting companies, end user clients and staff to eradicate this practice in the United Kingdom.
We are aware that by taking a best practice approach, this will aid with combatting slavery and human trafficking and ensure as a business we respect people and the communities in which they live. In addition, 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.
We are a provider of temporary labour solutions in various sectors within the UK labour market. We have our head office in Warrington in the UK. The Group has over 1,000 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 business is organised into nine business units:
- 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 Financial Limited – independent financial advisory services to temporary workers, personal service companies and micro-businesses in the UK.
- Brookson Limited – an accountancy practice providing specialist business support services to micro-businesses and personal services companies in the UK, as well as payroll services and back office support services to small, medium and large UK based businesses.
- Brookson Legal Services Limited – a legal practice providing specialist legal support services to micro-businesses, personal service companies and NHS organisations throughout the UK.
- Innova Financial Solutions Limited – independent financial advisory services to temporary workers, personal service companies and micro-businesses in the UK.
- Intouch Accounting Limited – an accountancy practice providing specialist business support
- services contractors and personal services companies in the UK.
- Boomerang Funding Solutions Limited – invoice factoring company and back office support for UK recruitment businesses.
- 1st Group of Companies – a group of businesses comprising accountancy and financial services.
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
- Consultancy Companies
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. 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 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 all the workers we engage in order to determine upon what basis they are intending to provide their services (as an employee or selfemployed) and we advise on each way of working in order to ensure the worker is comfortable operating in such a manner. As part of our process, we ensure that employees are no under undue influence from any third parties to accept employment with 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.
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 and in particular to those who are responsible for purchasing and human resourcing. 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 2018.
Chief Executive Officer
Date: March 2019