This statement is made pursuant to section 54 of the Modern Slavery Act 2015 (Transparency in Supply Chains) and sets out the steps Nicholas Associates Holdings Limited (together with its subsidiary undertakings, the “Group”) has taken during the financial year ended 31st December 2025 to help prevent modern slavery and human trafficking in our business and supply chains.
This statement was updated and approved by the Board on 21st April 2026 and is signed by a director on behalf of the Board. It will be published on our website homepage (or via a prominent link from the homepage) and may also be uploaded to the UK modern slavery statement registry.
Introduction
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. We 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.
Organisation structure, business and supply chains
The Group is a market leading partner of choice for talent management solutions. Our companies support businesses and individuals to develop their talent, from apprentices and graduates, flexible workers and permanent recruitment, through to leadership and software consultancy services and executive level search and selection.
As an organisation we are committed to being best in class by operating ethically and with a culture of giving back to society, maintaining our strong family values and sense of making a difference. Our International, National and Local charity partnerships align to this vision and our people help to raise awareness, generate essential funds and collaborate on joint initiatives with our charities.
Policies and governance
The Group policies include our Modern Slavery and Human Trafficking Policy where we confirm our zero-tolerance approach which 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.
We also operate a Whistleblowing policy to support and encourage our staff to report any wrongdoing which extends to Human Right violations like Modern Slavery.
Due diligence
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we 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 standards.
All new employees are shown our operating processes and made aware of our ethical and compliance standards. As part of this process, they are made aware of the indicators that would signal human trafficking and forced labour and how to report and deal with such an instance.
Assessing and managing risk
We recognise that risks of labour exploitation can arise in recruitment and labour supply, particularly where there are vulnerable workers, high levels of agency labour, complex subcontracting, or where workers may face language barriers, debt bondage, retention of identity documents, intimidation, or restricted freedom of movement. We assess and manage these risks through our compliance framework, including pre-engagement checks on labour providers where used, ongoing monitoring, and escalation routes. Where applicable in regulated sectors, we require relevant providers to hold appropriate licences (for example, under the gangmasters licensing regime overseen by the Fair Work Agency (FWA) (formerly the Gangmasters and Labour Abuse Authority (GLAA))) and to operate to standards aligned with our policies.
Training and awareness
Our stringent standards and commitment to compliance is paramount to us as an organisation. We support our teams with robust training and tight processes, monitored through audits and checks. We place great emphasis on every member of our Group being accountable and responsible for ensuring compliance is front-of-mind in everything we do, from right to work checks to protecting against Modern Slavery.
We operate within a highly compliant framework of processes and procedures to ensure our employees remain compliant against our own internal processes as well as against the Fair Work Agency (FWA) (formerly the Gangmasters and Labour Abuse Authority (GLAA)). All our employees are trained to understand the policy around Modern Slavery and Human Trafficking, how to identify and what steps to take if they suspect a case of Modern Slavery, and are supported by our Compliance Manager.
In addition to our internal training, policies and procedures, all of our employees are signposted to further information and supported and encouraged to further understand Labour exploitation and our responsibility. We raise awareness to all agency workers via the multi lingual section in the handbook and ask structured questions during candidate onboarding taken from the Stronger2gether training relating to key indicators of Modern Slavery. In addition to raising awareness amongst our agency workforce we have processes and policies in place such as a Whistleblowing Policy, acceptance of original RTW documentation only and non-acceptance of third party bank accounts.
Monitoring and effectiveness
We monitor the effectiveness of our approach and aim to continuously improve. Our key measures include:
- Reports raised (including via whistleblowing) relating to suspected exploitation, investigations completed, and outcomes/remedial actions taken.
- Compliance monitoring outcomes (for example, audit/check findings) and actions taken to address any issues identified.
- Supplier and labour provider engagement, including communication of our expectations and, where relevant, obtaining and reviewing modern slavery statements/policies.
- Payroll and worker due diligence checks (for example, checks for duplicate bank accounts/addresses, common contact details) and follow-up actions.
Where concerns are identified, we aim to respond promptly and responsibly, prioritising the safety and wellbeing of affected individuals, supporting access to appropriate help, and working with relevant stakeholders and authorities as needed. We also use learnings from any incidents or near-misses to strengthen our controls.
This statement was approved by the Board of Nicholas Associates Holdings Limited on 21st April 2026.
Signed for and on behalf of the Board:
Nick Cragg
Executive Chairman
Date of approval: 21st April 2026
