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Modern day Slavery & Human Trafficking Policy

Modern day Slavery
&
Human Trafficking Policy

1. Introduction

1.1 This document will outline the legal responsibility and moral duty of care that Owens Express Recruitment will apply in their effort to combat modern day slavery and human trafficking

1.2 Owens Express Recruitment are committed to driving out any real or potential risk of modern day slavery from its business and from those within their direct or indirect supply train

1.3 Owens Express Recruitment acknowledges its responsibility to the Modern Day Slavery Act 2015 and its impact on all current and future suppliers and customers

1.4 Staff and directors will ensure that all due diligence is applied when entering into negotiation with nay current or future clients regarding the recruitment or supply of staff.

1.5 In addition, the directors and appropriate staff will constantly review all current contracts to ensure that a robust and transparent process is in place.

1.6 This policy MUST be read in conjunction with the OER safeguarding, Equality & Diversity, Staff welfare and Recruitments policies.

1.7 The following definitions are relevant:
• Duty of care: the legal obligation to safeguard others from harm while they are in your care, using your services, or exposed to your activities
• Safeguarding: The actions taken by a responsible agent to protect the health, welfare and safety of any persons
• Child; A person who has yet to attain their 18th birthday
• Vulnerable person: A person who because of illness, age, mental health issues, a disability or any other reason whatsoever is not in a position to fully care for themselves

1.8 A copy of this policy will be made available to all staff at the induction process.

1.9 This policy will be reviewed yearly or as and when there are nay legislative amendments.

2. Responsibilities

2.1 The Directors will maintain responsibility to implement and drive this policy forward.

2.2 The Directors will ensure that appropriate and adequate training is designed and delivered to key staff to ensure that those responsible for recruitment, resourcing and day to day staff management to ensure they are aware of the signs pertinent to Modern Day Slavery.

2.3 All current, and any new contractors, in our supply train will be required to both acknowledge this policy and demonstrate a desire to support our objectives.

2.4 Owens Express Recruitment will not deal with directly or via a third party any organisation that does not share our objectives.

2.5 The following principles of duty of care apply;
• Staff must be vigilant to any activities or behaviour that may result in harm to any person
• Staff must ensure where practicable, that they take reasonable steps to keep people safe
• Staff must adhere to all organisational policies
• Staff must understand the underpinning legislation pertinent to Safeguarding, Employee welfare, Equality and Diversity and Modern Day Slavery

2.6 All staff must be vigilant to any actions or activities of any person that can lead to any harm being caused and must report their concerns immediately.

3. Administration

3.1 We have a duty of care for people who work for or who are subcontracted to nay of our clients

3.2 This is a continuous duty.

3.3 Staff must ensure that they raise any concerns to a supervisor as soon as possible

3.4 The supervisor must ensure that the incident report is completed and forwarded within 12 hours to the director responsible or their nominated deputy.

3.5 If required, the Director will immediately inform the Police and/or the Immigration Service

4 Legal Implications

4.1 Owen Express Recruitment acknowledge their legal, moral and ethical duty to combat Modern Day Slavery

4.2 The following legislations is pertinent to this document
• All Employment Acts
• The Data Protection Act 1998
• The Human Rights Act 1998
• Health and Safety at Work Act 1974
• Modern day Slavery Act 2015
• Children’s Act 2004
• Equality Act 2010

4.3 Owens Express Recruitment acknowledge that they have a duty to protect and safeguard anyone who they come into contact with through their business dealings- be that directly, vicariously or via any third party.

4.4 This policy is a fully disclosable document