This statement has been published in line with the requirements of the Modern Slavery Act 2015 and sets out the Company’s position on the prevention of modern slavery and human trafficking for the year ending December 2022. It was approved by the Board of Directors in December 2022, being signed off by our Company Director, Stephen Collinson.
NE European Recruitment LTD takes the issue of modern slavery very seriously with a zero-tolerance approach to the subject with continual review by the Board and our Operational teams. We work with our clients and registered work seekers as part of our attempts to expose any incidents of modern slavery in the workplace. Our efforts have continued throughout 2022 and we are pleased to report that no incidents were identified in the last year. We are in support of the Act and will not knowingly work with any businesses found to be involved in modern slavery.
NE European Recruitment LTD is a limited company operating as both an employment agency and business in the UK.
NE European Recruitment LTD was founded in 2007 and operates solely within the UK providing temporary and permanent recruitment services. We specialise in supplying office based and light industrial workers across all industry sectors. Our workforce is therefore not only made up of our permanently engaged employees but also our registered work-seekers.
We operate from 1 office based in Hartlepool with a permanent workforce of 4 people.
The size of our temporary workforce fluctuates throughout the year.
All the companies/organisations we supply and all the work-seekers we provide to them are met with and identified by our staff. The hiring organisations that we work with are all located in the UK. The work-seekers/ workers we supply live in the UK.
NE European Recruitment LTD currently makes minimal use of other agencies in the supply of our recruitment services; therefore, our supply chain is limited to the use of suppliers providing goods and services such as IT equipment and stationery.
NE European Recruitment’s LTD policies are established by our Board of Directors, based on advice from HR professionals, industry best practice and legal advice. We review our policies on a regular basis, and as needed, to adapt to changes.
As a company we have the following relevant policies in place:
• Modern Slavery and Human Trafficking Policy sets out our zero‐tolerance approach to modern slavery and our commitment 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
• Ethical Purchasing Policy stipulates the conditions under which the Company will conduct its business in respect of the procurement of all externally supplied goods and services and requires our supply chain to provide positive assurance towards, including but not limited to, zero tolerance on human trafficking and use of any form of forced or compulsory labour and freedom of employees
• Code of Business Conduct and Ethics promotes honest and ethical conduct throughout the Company, as well as provides a mechanism to report unethical conduct via the Ethics Hotline to help preserve our culture of honesty and accountability and is part of our annual update training undertaken by all employees.
• Corporate Social Responsibility Policy reflects our commitment to support socially productive activities to make our world a better place. What we do helps to change lives and communities for the better. NE European Recruitment LTD provides people with training and job opportunities that help them to transform their lives, and this puts social responsibility at our core
• Whistleblowing Policy sets out our position on whistleblowing and encourages the reporting of any legal or regulatory violations or any failure to comply with internal regulations, ethical standards and legislation impact.
These policies are available to all employees in the Company Handbook provided and are first introduced as part of their initial on-boarding induction when joining the Company. Adherence to our policies is expected of all employees.
Any employee who breaches our policy on Modern Slavery and Human Trafficking 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 do not meet our corporate expectations.
We review our policies and procedures on a regular basis and as legislation may dictate to ensure not only ongoing compliance to our standards but also that our supply chain shares the same principles and commitment to the Modern Slavery Act.
Our standard practices are designed to protect and promote human rights and fair labour practices throughout the recruitment, selection and employment of both our employees and the work-seekers we place with our clients.
NE European Recruitment LTD operates within all applicable recruitment legislation.
During 2022:
• All existing employees have completed refresher ethical, including modern slavery training annually, part of which includes the Modern Slavery policy
• All employees have been advised on how they can report any concerns they may have associated with Modern Slavery
• Our Payroll Department carried out regular checks on our workers bank details to identify where individuals may be sharing bank accounts, or addresses, as this could be an indication of illegal behaviour
• All workers continue to have on-line access to their weekly pay records allowing them to view all deductions we legally make from their salaries.
A commitment to human rights, fair labour practices and ethical business dealings is essential to our principle based culture.
NE European Recruitment LTD:
▪ Has held a corporate Gangmasters Licence since the inception of the Gangmasters and Labour Abuse Authority (GLAA), formally known as the GLA, which was formed as an independent body arising out of the Gangmasters (Licensing) Act 2004. Its Mission Statement is to work in partnership to protect vulnerable and exploited workers
▪ Joined the Association of Labour Providers (ALP) a not-for-profit trade association promoting responsible recruitment within the food industry
▪ Seeks positive assurance, within our UK supply chain, that they agree to comply with the principles of our Corporate Social Responsibilities Policy, which forms part of the contract with our supply chain. Where appropriate, we carry out due diligence on prospective suppliers, as well as auditing existing and prospective suppliers about legal and contractual compliance
▪ Takes a risk-based approach to addressing concerns that may arise from our supply chain. Modern Slavery considerations are included as part of our risk management and supplier selection processes. We also review how we align with our suppliers on this issue. We expect all suppliers to operate in accordance with our Supply Chain Business Partner Policy. We procure that our supply chain disseminates these terms down to their own suppliers and subcontractors.
We are committed to ensuring there is transparency in our own business and in our approach to tackling unethical business practices, including modern slavery, throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
There haven’t been any breaches of the Modern Slavery Act reported during 2022. Moving forward we will look to include specific KPI’s to measure our success.
Our Code of Business Conduct and Ethics provides guidance to all our staff on the conduct of our business according to the highest moral standards. The Code and our other ethics policies help to focus our staff on the areas of this type of risk. It offers guidance in recognising and dealing with any ethical issues and provides mechanisms to report unethical conduct without fear of retaliation.
The code provides a compliance hotline for employees to inform (on an anonymous basis) any concerns with activities of the Company or the supply chain. This can be found in Company’s Handbook.
Additionally, where we have supply arrangements in a sector where the use of modern slavery practices is a known concern (e.g. food pickers and packers), we have introduced further training for the recruitment teams involved ( Advanced Workshop – Tackling Modern Slavery in Supply Chain Stronger Together). Our membership of ALP has also provided us with access to further training resources on this and other recruitment processes.