This statement is made as part of Engage Partners commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Engage Partners operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, as well as how we train our staff.
This statement is published in accordance with section 54 of the Act and relates to the financial year April 2021 to April 2022. It was approved by the board of directors 12th April 2021.
This statement constitutes Engage Partners Groups’ modern slavery and human trafficking transparency statement as of May 2018. The statement sets down Engage Partners commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
Engage Partners is a limited company operating in the recruitment sector. We provide introduction services and supply temporary workers in the education and construction sectors. Engage Partners is an independent business.
WHO WE WORK WITH
All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. We do not supply work-seekers to hiring companies through any intermediaries. The hiring companies that we work with are located in the UK. The workers we supply live in the UK, Ireland, Canada, Australia, South Africa, and the UAE.
As part of our business, we also work with the following organisations:
- The Department for Education
- Crown Commercial Services
- the Recruitment and Employment Confederation (www.rec.uk.com)
Engage Partners has a modern slavery policy that is available to view on our website. In addition, Engage Partners has the following policies which incorporate ethical standards for our staff and our suppliers. To view a list of our data processing policies, please visit the Privacy page on our website: https://engage-education.com/privacy/
Policy Development And Review
Engage Partners’s policies are established by our senior leadership team, which include our CEO, Head of Education and Head of Marketing, based on advice from HR professionals, industry best practice and legal advice, and in consultation with our Head of HR, HR advisory consultants and the REC. We review our policies on a regular basis, or as needed to adapt to changes.
Our Processes For Managing Risk
In order to assess the risk of modern slavery, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.
After a review of our business activities, the Management can confirm that there are no high-risk activities or at risk of modern slavery or human trafficking.
Responsibility for the Company’s anti-slavery initiatives is as follows:
- Policies: The Head of HR is responsible for creating and reviewing policies. The process by which policies are reviewed is on an annual basis whereby they will look at industry best practices and implement any relevant amendments to the Company.
- Risk Assessments: The Office Manager is responsible for risk assessments in respect of human rights and modern by a process of reviewing our business activities, confirming the right to work of all candidates and that the rates of pay for all candidates are in accordance with the local legislation.
- Due Diligence: The Finance Director is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking. The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes a review of their financial history, what governing or regulatory body they are a member of, and customer references if a material supplier. Our aim is to build long-standing relationships with suppliers and making clear our expectations of business partners.
Additionally, we have taken the following steps to minimise the possibility of any problems:
- We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
- We require the businesses we work with to publish a modern slavery statement.
- We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
- Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
- Our staff are encouraged to bring any concerns they have to the attention of management.
As part of monitoring the performance of Engage Partners, we track the following general key performance indicators:
The level of training amongst our staff;
The speed with which we investigate related complaints, and the effectiveness of our whistle-blowing procedures;
The level of compliance and transparency we have established in our supply chain.
Review of our sage payroll and CRM to review our employee and candidate salaries to ensure they are above the national living wage.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Board of Directors endorses this policy statement and is fully committed to its implementation.
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by the senior leadership team:
- The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
- The level of modern slavery training and awareness amongst our staff
We carefully consider our indicators, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.
All of our staff receive training and support that is appropriate to their role. In particular:
- Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
- Our recruiters undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking so that they can bring any concerns they have to the attention of management. As part of this, our staff are encouraged to discuss any concerns that they have. Training is refreshed annually.