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Modern Slavery and Human Trafficking Policy

INTRODUCTION:

This policy has been agreed by the Directors of Barker Ross Group Limited, and applies across all operations of the Group activity.  This includes Barker Ross Staffing Solutions Limited, Barker Ross Recruitment Limited and Cardea Resourcing Limited, T/A Barker Ross Health and Social Care.

This policy is reviewed and published annually, each January, following our company year end, which is the preceding November.  We share this policy to all employees and it is also shared via our website: www.barkerross.co.uk and can also be found at TISCreport.org and modernslaveryregistry.org.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Barker Ross Group have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.  As a labour only supplier, our supply chains are minimal and limited to other services (utilities, IT provision) and stationery.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee's contract of employment and we may amend it at any time.


RESPONSIBILITY FOR THE POLICY

 • The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it

 • The Group Quality Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery

• Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains

• You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Group Quality Manager


COMPLIANCE WITH THE POLICY

• You must ensure that you read, understand and comply with this policy

 • The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy

 • You must notify your line manager and the Group Quality Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future

• You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage

• If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your line manager and the Group Quality Manager OR report it in accordance with our Whistleblowing Policy as soon as possible

• You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains

• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the Group Quality Manager

• We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern

 • If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current staff handbook


COMMUNICATION AND AWARENESS OF THIS POLICY

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.


COORDINATION AND COOPERATION

Barker Ross has considered the risk to individuals and has developed processes to ensure that the likelihood of occurrences of modern slavery occurring are minimised.   In our last financial year Barker Ross paid over 12,000 unique individuals.  Of this number, we suspected 4 instances where individuals may have been subject to exploitation under Modern Slavery.  Each of theses instances were reported to the GLAA and we were able to support the subsequent external investigations. 

Barker Ross has links with the Gangmaster and Labour Abuse Authority (GLAA) through its registration and certification.  Any allegations of abuse will be reported to the Police and the GLAA and Barker Ross will work in partnership with these bodies to prevent the exploitation of vulnerable workers. 

It is our policy to monitor the well being of all workers covered by our GLAA registration and ensure that our clients understand how important it is to our business that all practices are fair, ethical and transparent. 

Our registration process includes checks to monitor and audit details that have been provided to us by candidates.  All candidates are asked the ‘Stronger Together’ questions as part of their registration process and candidates are paid weekly, into their own bank accounts.  Any complaints or concerns raised by a worker will be shared with our Group Quality Manager, who will investigate and liaise with the HR Manager and Managing Director.  If a breach in legislation appears to have occurred a report of our suspicions is made to the Police and to the GLAA.  Similarly, if a Recruitment Consultant is aware of an issue affecting the workers, it is our policy that this concern be reported to the Group Quality Manager and HR Manager to be followed up and investigated, with further liaison with the GLAA and Police.


BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.