Modern Slavery Policy
1.1. Our business, Recruitment Bee (Scotland) Limited; herein known as Recruitment Bee is committed to combatting slavery and human trafficking in its business and supply chains, and we make this policy to assist with compliance with the Modern Slavery Act 2015. As our business has a turnover of less than £36 million, we do not have a legal obligation to produce a modern slavery statement.
a. We agree that exploitation within all supply chains ending in the UK is a blight on our society,
and we are committed to playing our part in eliminating exploitation;
b. We understand that customers with obligations under the Modern Slavery Act 2015 cannot
comply with those duties without our cooperation.
This Policy sets out the Company’s zero-tolerance approach to modern slavery. The Company is committed to acting ethically and with integrity in all its business dealings and relationships and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its business operations or in any of the Company’s supply chains.
1.2. Modern slavery is a crime and a violation of fundamental human rights. The Company recognises this 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.
1.3. The Company is committed to ensuring there is transparency in its business and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. The Company expects the same high standards from all of its suppliers, contractors and other third parties. As part the Company’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards set out in this policy.
1.4. The Company Director has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all those staff and third parties under its control comply with it.
1.5. This policy does not form part of any employee's contract of employment and the Company may amend it at any time.
Who does this Policy Apply to?
2.1. This policy applies to all persons working for Recruitment Bee (Scotland) Limited (the “Company”) or on its behalf in any capacity, including employees at all levels, directors and officers (“Staff”) , and third parties including agency workers, customers, suppliers seconded workers, volunteers, interns, agents, contractors, external consultants (“third parties”).
Scope and Purpose of the Policy
3.1. This policy describes how the Company will prevent, detect and report modern slavery in any part of its business or supply chains.
3.2. The Company aims 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. The Company is 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 the business or in any of the Company’s supply chains.
Compliance with the policy
4.1. All staff and third parties must comply with this policy and are required to avoid any activity that might lead to, or suggest, a breach of this policy.
4.2. All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the Company’s business or supply chains of any supplier tier at the earliest possible stage.
4.3. If any staff believe or suspect a breach of this policy has occurred or that it may occur the individual must notify either the Company Director who will report a suspicion or seek advice by contacting the Modern Slavery Helpline confidentially on 08000 121 700. This is open 24 hours a day, 365 days a year. Third parties should notify a senior Company point of contact.
4.4. If staff or third parties are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the Company’s supply chains constitutes any of the various forms of modern slavery, this should be raised as set out in paragraph 4.3.
4.5. The Company Director is responsible for ensuring that this policy and the Company’s zero-tolerance approach to modern slavery is communicated to all employees and for ensuring those individuals reporting to them understand and comply with this policy and are given adequate and regular training as applicable on the policy and the issue of modern slavery in supply chains.
4.6. The Company Director has 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.
4.7. The Company Director is responsible for procurement of goods and / or services and will ensure that this policy and the Company’s zero-tolerance approach to modern slavery is communicated to all third parties during the procurement process and / or at the outset of each business relationship.
4.8. The Company Director is responsible for ensuring that all relevant existing third-party contracts include obligations to comply with the Modern Slavery Act and new third-party contracts contain applicable prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.
4.9. All staff will undergo Modern Slavery training and annually thereafter using up to date information and promotional videos as highlighted on Gov.UK website https://www.gov.uk/government/collections/modern-slavery
Investigations & Disciplinary Action
5.1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2. The Company may terminate its relationship with other third parties if they breach this policy.
Review of the policy
The Company Director has overall responsibility for reviewing this policy and will do so annually.