Modern Slavery Statement

Modern Slavery and Human Trafficking Statement

INTRODUCTION

Comity Recruitment Ltd recognises that all businesses have an obligation to prevent slavery and human trafficking and will do all in its power to prevent slavery and human trafficking within its business and within the supply chains through which it operates.

Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. We take our responsibility for supplying staff extremely seriously and are aware of the potential of being a target by traffickers and unlicensed gangmasters. Our own processes around candidate engagement ensure our employees are alert to the signs of exploitation, in order that we may take the necessary action promptly and effectively should it be identified. Sectors affected include, but are not limited to, construction & property, engineering & manufacturing and health & social care.

This statement focuses specifically on Comity Recruitment Ltd’ compliance with the Modern Slavery Act 2015 (the Act) and highlights the steps we take to ensure there is no slavery or human trafficking occurring within the organisation or its supply chains. One of our company’s most valuable assets has always been its reputation for integrity and fairness. Maintaining this reputation within our market is an essential pre-requisite to our continued success.

OUR BUSINESS

Our business consists of recruitment across the following Industries:
Parking Enforcement, Security Personnel, Facility Management, Warehouse, Information Technology, Health & Social Care, Cleaning, Office Professionals, Retail.

OUR SUPPLY CHAINS

Our supply chains include, but are not limited to, sourcing candidates for clients. This may involve the introduction by external agencies to Comity Recruitment Ltd of candidates for onward supply to our clients. We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner by adhering to our Supplier Code of Conduct. We also expect our suppliers to promote similar standards in their own supply chain.

OUR POLICIES INCLUDING ON SLAVERY AND HUMAN TRAFFICKING

Suppliers are expected to adhere to our Supplier Code of Conduct, which includes specific reference to the Modern Slavery Act 2015, and should have in place a policy recognising, respecting and protecting the human rights of their employees, those of their suppliers and business partners and the communities affected by the suppliers’ operations.

Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.
All employees must be provided with a clear contract of employment, which complies with local legislation.
All employees must be treated in a fair and equal manner and with dignity and respect.
Any form of discrimination, victimisation or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependants, religious belief or political opinion, age, trade union activity and offending background should be prohibited.

All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to, without any unauthorised deductions. Suppliers should observe the provisions of the International Labour Organization such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.

All slavery and human trafficking laws must be complied with including, but not limited to, the UK Modern Slavery Act 2015. Suppliers must ensure their business operations are free from slavery and human trafficking practices whether in the UK or elsewhere, both internally and within their supply chains and other external business relationships. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

DUE DILIGENCE PROCESS FOR SLAVERY AND HUMAN TRAFFICKING

Comity Recruitment Ltd ensure strict compliance checks are carried for all candidates it supplies. We verify the identity of each worker and their right to work before supply commences.
As part of our commitment to identify and eradicate slavery and human trafficking, we have in place a process to undertake due diligence on our supply chain network to ensure compliance with legislative obligations; the scope and reach of this process will continue in future years.
All Comity Recruitment Ltd employees have access to dedicated channels through which they may voice concerns, through local reporting mechanisms. Comity Recruitment Ltd is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially and without fear of retaliation.

TRAINING

All staff within Comity Recruitment Ltd are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. We have undertaken to review our policies and procedures to ensure our colleagues have access to any additional information and support they may require with regard to human trafficking, forced labour, servitude and slavery. A training module on modern slavery and human trafficking is also available to all employees.
This statement is made to pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes Comity Recruitment Ltd’ slavery and human trafficking statement for the current financial year.

Thompson Awoyemi
Compliance Manager For and on behalf of Comity Recruitment Ltd

May 2018