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Modern Slavery Policy

MODERN SLAVERY STATEMENT
This statement is made as part of Spectrum Recruitment Limited commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how Spectrum Recruitment Limited operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff. 
This statement is published in accordance with section 54 of the Act, and relates to the financial year January 2017 to December 2017.   It was approved by the Managing Director on the 30th May, 2017. 
Suzanne Letting
Managing Director

1 OUR BUSINESS
Spectrum Recruitment Limited is a Limited company operating in the recruitment sector.  We provide introduction services / supply temporary workers / act as a neutral vendor / and/or act as a master vendor in the Commercial, Industrial, Catering, Events sectors.
Spectrum Recruitment Limited is an independent business. 
1.1 Who we work with
All the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff.  All the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies.
The hiring companies that we work with, are located in Bedfordshire, Buckinghamshire, Milton Keynes, Northampton & Midlands.  The work-seekers/workers we supply live in the areas mentioned above.
1.2 Other relationships
 The Recruitment and Employment Confederation (www.rec.uk.com)
 The Institute of Recruitment Professionals (www.rec-irp.uk.com)

2 OUR POLICIES
Spectrum Recruitment Limited has a Modern Slavery Policy which can be seen on request.

In addition, Spectrum Recruitment Limited adopts policies which incorporate ethical standards for our staff and our suppliers which are recommended by the REC, Recruitment and Employment Confederation of which we are Corporate Members.
2.1 Policy development and review
Spectrum Recruitment Limited policies are established by our directors and our senior leadership team, based on the advice from our HR professionals, industry best practice and legal advice, and in consultation with REC Legal Advisors.  We review our policies annually, or as needed to adapt to changes in legislation.

3 OUR PROCESSES FOR MANAGING RISK
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
• When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
• We conduct audits before entering into a commercial relationship with any business where there is the potential for risk.  These audited businesses form the basis of our preferred supplier list.
• We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
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.  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 abide by our code of supplier conduct / address modern slavery concerns in their policies / 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.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
Our staff are encouraged to bring any concerns they have to the attention of management.


4 OUR PERFORMANCE
As part of monitoring the performance of Spectrum Recruitment Limited, we track the following general key performance indicators: 
• That all hiring Clients are Credit Checked
• That all hiring Clients provide detailed job orders
• That all worker/work seekers are interviewed, assessed and ability to work in the Uk is verified
• That all worker/work seekers are supported in their assignments
• That any concerns of Modern Slavery are notified to the Managing Director
We benchmark our indicators against industry best-practice, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.


5 OUR TRAINING
All of our staff receive training and support that is appropriate to their role.  In particular:-
• 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, and provided to any new members of staff.


MODERN SLAVERY POLICY

 Spectrum Recruitment Limited

1. Spectrum Recruitment Limited is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses. 

2. Spectrum Recruitment Limited is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses. 

3. Spectrum Recruitment Limited provides appropriate training and awareness information for all Consultants of its staff. 

4. In particular:
• Our Directors receive detailed information from the REC in identifying and resolving concerns around modern slavery and human trafficking.
• 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.


5. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to Suzanne Letting, Managing Director.

6. Reports surrounding these issues are taken extremely seriously by our Managing Director, who is committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

• Passing details to appropriate law enforcement bodies.

7. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
• The level of modern slavery training and awareness amongst our staff.


8. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

9. We would also recommend reading this in conjunction with our other policies, including our:

  •  Corporate social responsibility policy
  •  Ethical procurement policy
  •  Anti-bribery / corruption policy, and
  •  Whistle-blowing policy.

This policy was adopted on 30th May, 2017 after being agreed by our Managing Director.  It is reviewed. annually unless otherwise directed by Legislation.