Modern Slavery and Human Trafficking Statement
1. Purpose This statement (the Statement) is made on behalf of Peel Recruitment and Training Solutions Limited) pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act).
Peel takes its obligations in relation to the identification, prevention and reporting of modern slavery and human trafficking very seriously and has a zero-tolerance approach to the abuse of human rights.
Peel adheres to a worldwide group Code of Ethics personally supported by all staff, and pursuant to this undertakes to comply with the strictest legal and moral standards in the conduct of its operations.
2. Policies in relation to modern slavery and human trafficking Peel has a number of policies and procedures
which are relevant to preventing instances of modern slavery from occurring in its business or its supply chains, including having a dedicated compliance team to whom breaches of any of the following policies can be notified.
In particular, the following policies are directly relevant to the subject matter of this Statement:
3. Code of Ethics – this requires employees to comply with the principles of the United Nations Universal Declarations of Human Rights,
the fundamental conventions of the International Labour Organisation, in particular, concerning forced child labour and the principles of the United Nations Global Compact;
• Health & Safety policy – this policy sets out Peels’ commitment and approach to ensuring it provides a healthy, safe working environment for its own staff and contractors that work on-site;
• Harassment & Bullying policy – this policy sets out Peels’ approach to preventing the occurrence of discrimination, harassment, bullying or victimisation in the work place;
• Authority limits and contract signing policy – this policy sets out Peels’ internal control and governance procedures with regard to approving financial transactions and signing contracts with suppliers.
The policy ensure that contracts cannot be entered into without an appropriate level of review and authorisation by a suitably senior and qualified member of staff;
• Whistleblowing policy – this policy encourages employees to bring any bad practice they become aware of to the attention of senior management without fear of repercussions for doing so; and
• Anti-slavery policy – this policy specifically addresses the subject matter of the Act recognising and preventing trafficked, forced, bonded and child labour.
4. Due diligence processes Peel and its suppliers are expected to live up to and adhere to the principles set out in the anti-slavery policy
and demonstrate progress towards the standards set out in it.
Peels’ procurement practices require that all new suppliers are subject to an appropriate level of screening.
The scope of the screening Peels performs depends on the nature of the goods or services being procured but can include financial checks,
data security assessments, reference checks, obtaining copies of relevant documents and/or site inspections.
5. Risk assessment and management Section 2 above sets out the areas of Peels’ procurement activity where there could be a risk of slavery or human trafficking taking place.
Peel assesses and manages the procurement of high value and/or high-risk goods and services in accordance with Peel’
procurement practices and formal tendering procedures.
Peel also employs a compliance officer to ensure compliance with its legal and ethical obligations.
Peel provides its employees with access to an employee assistance programme (provided by an independent third-party company)
that can be used by its employees for free and confidential advice in relation to workplace concerns or issues.
It also has in place appropriate processes for reporting concerns with the business, including a whistleblowing policy and a designated Compliance Officer.
A statement has been made by our Directors to all staff asking all staff to be vigilant in our workplaces in respect of potential labour exploitation
and to report anything giving rise to a suspicion in this area.
As a matter of best practice going forward, Peel includes model clauses on the Act in all of its contracts with suppliers,
subcontractors and consultants requiring compliance with the Act permitting termination for breach.
6. Evaluating Peels’ effectiveness: We have not found any evidence of practices that violate the Code of Ethics or Anti-slavery policy including the values that relate to modern slavery and human trafficking.
We have principles that assist decision making in the event of a breach of standards, for example a requirement to address any breach immediately and for a full investigation to follow.
We are currently creating a more detailed process for addressing non-compliance.
7. Training in relation to slavery and human trafficking Peel has developed a CPD accredited a programme of slavery and human trafficking awareness training
for its teams and the individuals in its business with responsibility for managing suppliers in medium to high risk areas.
The purpose of training will be to raise awareness of slavery and human trafficking as a problem that could potentially affect Peels’ supply chain,
provide assistance in identifying medium and high-risk suppliers and behaviours and provide for detailed understanding of
Peels procedures in relation to medium and high-risk suppliers.
8. Conclusion This Statement was approved by the Board of Peel Recruitment and training solutions Limited on behalf of Peel, on 01 September 2017.
It was reviewed and approved by each of the individual entities comprising Peel which has obligations under the Act.