This statement is in accordance with the Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking has not taken place in our supply chains or in any part of our Business.
This statement also informs of the steps we take to prevent modern slavery and human trafficking in our Business and supply chains.
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.
Organisational Structure, Business & Supply Chains
Nicholas Associates 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.
Nicholas Associates 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 Processes
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.
Risk Assessment & Management
Within the regulated sector, any recruitment businesses who we engage with for the supply of temporary workers to Nicholas Associates Group will be licensed by the Gangmasters Labour Abuse Authority (GLAA) and will work to the same strict standards as per our own operating procedures.
Modern Slavery Training
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 Gangmasters 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 who has attended the Stronger2gether workshop and the GLAA national conference.
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 temporary employees via the multi lingual section in the handbook and ask structured interview questions taken from the Stronger2gether training, these relate to key indicators of Modern Slavery. In addition to raising awareness amongst our temporary 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.
Assessment of Effectiveness
The following Key Performance Indicators have been agreed to monitor our effectiveness;
- Investigations undertaken into reports of Modern Slavery and remedial actions taken.
- Employees knowledge of Modern Slavery spotting the signs and how to report.
- Actions taken to improve communication of our expectations to suppliers and clients – Circulate Group Policy to our suppliers and clients as well as obtaining copies of their own policy and statement.
- Internal training to improve awareness amongst the senior and operational management teams.
- Implementation of further checks and audits
- Payroll department to undertake monthly checks on duplicate accounts and addresses.
- Operations to check for common telephone numbers, duplicated emergency contact details.
- View the worker’s bank card to cross reference bank details and name and ensure the account holder is in possession of his/her bank card.
- Request copies of tenancy agreements to identify any common landlord details.
This statement was approved by the Board of Nicholas Associates Holdings Limited.
26th February 2020