Modern Slavery Statement 24 - 25
Modern Slavery Statement
Modern Slavery can take many forms, and is not always obvious. Cases of modern slavery are happening all the time and often on our doorstep go un-noticed. Modern slavery can take many forms including human trafficking, forced labour, exploitation of children or vulnerable adults and domestic servitude. Hewett Recruitment are passionate about protecting the workers they provide to clients and proactively apply processes to their recruitment & selection and supply chain to help eradicate any form of slavery.
This statement is made as part of Hewett Recruitment’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).It summarises how Hewett Recruitment 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 April 2024 to March 2025. It was approved by the board of directors on 17th May 2024.
1 Our Business
Hewett Recruitment is a limited company operating in the recruitment sector. We provide introduction services and the supply temporary workers in Industrial, Engineering, IT & Technical, Financial and Commercial sectors.
Hewett Recruitment is an independent business.
1.1 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. Some of these work-seekers operate through their own limited companies. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.
1.2 Other relationships
As part of our business, we also work with the following organisations:
sector-specific professional and regulatory bodies
the Recruitment and Employment Confederation (www.rec.uk.com) and the Institute of Recruitment Professionals (www.rec-irp.uk.com)
Gangmasters Licencing Authority www.gla.gov.uk
2 Our Policies
Hewett Recruitment has a modern slavery policy. In addition, Hewett Recruitment has the following policies which incorporate ethical standards for our staff.
Equality & Diversity Policy
Customer Service & Complaints Policy
Whistle Blowing Policy
Anti-Corruption & Bribery Policy
REC Code of Ethics
2.1 Policy development and review
Hewett Recruitment’s policies are established by our leadership team, based on advice from HR professionals, industry best practice and legal advice, and in consultation with any relevant governing or regulatory body. We review our policies annually, or as needed to adapt to changes.
3 Our Processes for Managing Risk
Hewett Recruitment recognise the importance of all staff having awareness of the severity of modern slavery and as such have introduced the following processes and checks into its day to day recruitment of temporary workers:
- Red Flag Checklist
- Modern Slavery Worker Questionnaire
- Development of an ‘Escalation Process’
- Temporary Workers Welcome pack
- Formal monthly auditing of key flag data areas
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
We review the potential for risk at regular intervals including the possibility of re-auditing a supplier or conducting spot checks.
Reviewing our supplier list
Identifying potential risks based on nature of business and sector
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 collaborate with our suppliers in order to improve standards and transparency across our supply chain by asking suppliers if they have their own Modern Slavery Policy/Statement
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 Hewett Recruitment, we track the following general key performance indicators:
the percentage of workers supplied from audited businesses / our preferred supplier list. This is generally zero as we source our own workers.
the effectiveness of enforcement against suppliers who breach policies
the amount of time spent on audits, re-audits, spot checks, and related due diligence
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.
5 Our Training
All of our staff receive training and support that is appropriate to their role. In particular:
All of our staff receive informal awareness training as part of their initial staff induction, information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of Directors. Further refresher training is provided on an annual basis.
The ‘Red Flag list is discussed and the Modern Slavery Policy is explained in depth.
As part of this, our staff are encouraged to discuss any concerns that they have. Training is refreshed when required and forms part of the formal employee induction programme.
A dedicated training module on Modern Slavery is provided via our online training provider iHasco. This ensures all staff have awareness training surrounding Modern Slavery and ensure this topic is at the forefront of all staff’s mind, in particular Temp consultants as they are the first line of defence and for Payroll.
Modern Slavery Policy
Hewett Recruitment is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
Hewett Recruitment 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.
Hewett Recruitment provides appropriate training and awareness information for all of its staff.
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.
Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to a director of the business
Reports surrounding these issues are taken extremely seriously by our board of directors, who are 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:
Working with the appropriate organisations to improve standards including
i. Stronger Together
ii. Hope for Justice
iii. Recruitment & Employment Confederation
Removing any individual from such a situation where appropriate
Removing that organisation/individual from our supply chain,
Passing details to appropriate law enforcement bodies.
6. We regularly monitor our risks in this area at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks. Monthly checks of temporary workers data include:
Addresses – checking for multiple occupancy of either one residence or black of flats, close proximity
Contact numbers: checking for same contact numbers of sequential numbers leading in to potential control of workers by and individual issuing multiple phones
Next of Kin: checking for potential non-related names individuals or same contact for multiple individuals
Bank details: checking if bank account is in own name, no duplicate bank account numbers etc
Change of bank details: ensuring any subsequent request or change of bank details also match the individual personally
7. We have in place a number of processes and systems in place to deliberately test for and help identify vulnerable workers including:
Numeracy and English Test – these tests are to ensure the level of comprehension and understanding by temporary workers. These tests are administered on site and are competed alone with no support or intervention from anyone accompanying the worker. (The English test also ensures sufficient comprehension of the English language from a Health & Safety perspective for individuals entering the workplace)
Face to face interviews - all potential workers are required to undertake a face to face interview, an opportunity for the consultant to explore their work experience, circumstances and ability to perform the job they are applying for. If any individual is seen to speak on behalf of a worker then the applicant is removed and an interview conducted in private.
No use of interpreters - we do not permit the use of interpreters. From a H&S perspective individuals must have suitable command of the English language to be able to respond swiftly and safely in case of emergency at their place of work. Those who are unable to demonstrate clear communication are encourage to go away and practice their use of the English language and return when they feel their level has improved to a sufficient level. This limits the risk of individuals being spoken for and potential for incorrect information or force being used on an individual who cannot communicate freely or themselves.
Modern Slavery Worker Questionnaire: a list of interview questions specifically relating to modern slavery have been adopted to help identify any potential flags or concerns. This is used as and when red flags have been identified.
ID and Right to Work Checks
Proactively working on verifying EU Worker Settlement Status
Red Flag Checklist – posters in the office and provided at induction as a reminder of potential flags for identifying vulnerable individuals and may act as a prompt for individuals to self-identify.
Development of an ‘Escalation Process’: any and all concerns relating to potential modern slavery are escalated directly to a company director
Temporary Workers Welcome Pack: includes the addition of a dedicated section on modern slavery, highlighting to individuals the importance Hewett’s place on tackling modern slavery. It is hoped this will provide peace of mind for candidates and offer information to help individuals self-identify as well as acting as a deterrent to potential traffickers.
Car Sharing – we do not permit car sharing, which could encourage multiple occupants of houses or those under control being shipped to site by a controlling individual. This is also to ensure that each worker is responsible for attending site (should the owner of the vehicle be unable to attend work this could render several temporary workers unable to attend site and cause a detriment to the service we provide to our clients).
Formal monthly auditing of key flag data areas: Monthly auditing is in place in order to cross-check data for similarities/duplications in temporary worker data.
Addresses – checking for multiple occupancy of either one residence or black of flats, close proximity
Bank details: checking if bank account is in own name, no duplicate bank account numbers etc
As part of our efforts in this area, we publish a modern slavery statement on an annual basis.
8. We would also recommend reading this in conjunction with our other policies, including our:
Equality & Diversity Policy
Customer Service & Complaints Policy
Whistle Blowing Policy
Anti-Corruption & Bribery Policy
REC Code of Ethics
This policy was adopted in April 2017 after being agreed by our Board of Directors. It is reviewed annually to ensure it continues to support the organisations commitment to eliminating Modern Slavery.