Modern Slavery & Human Trafficking Policy

Introduction

We are committed to conducting business ethically, responsibly and with integrity.

CCR Recruitment Limited recognises its responsibility to combat modern slavery and human trafficking in all its forms and is committed to ensuring that slavery, servitude, forced labour, debt bondage and human trafficking do not occur within our business operations or supply chains.

We support the principles set out within the Modern Slavery Act 2015, the International Labour Organisation (ILO) Conventions, the United Nations Guiding Principles on Business and Human Rights and all applicable employment legislation.

Company Commitment

We are committed to this Policy and shall ensure it is communicated throughout our business and supply chain.

As a recruitment business operating within the construction, engineering, infrastructure and industrial sectors, we recognise that labour supply chains can present heightened risks in relation to modern slavery and exploitation.

We are committed to promoting fair working practices and ensuring that all workers supplied by or through CCR Recruitment Limited are treated with dignity, fairness and respect.

Our Business and Supply Chain

We work with a wide range of:

• Clients
• Candidates
• Contractors
• Subcontractors
• Labour providers
• Suppliers
• Professional advisers
• Technology partners

Many of these organisations operate through complex contractual relationships and may engage additional suppliers and subcontractors.

We expect all organisations associated with our business to uphold the same commitment to ethical employment practices and compliance with applicable legislation.

Due Diligence Processes

We shall:

• Operate recruitment and onboarding processes designed to verify worker identity and right to work
• Conduct appropriate checks on labour suppliers and subcontractors
• Require suppliers and contractors to comply with the Modern Slavery Act 2015 and all applicable employment legislation
• Assess and monitor areas of higher risk within our labour supply chains
• Include appropriate contractual obligations requiring ethical employment practices
• Refuse to engage with organisations where evidence of exploitation or modern slavery exists
• Follow government guidance and industry best practice relating to modern slavery prevention
• Maintain records of compliance checks where appropriate
• Review supplier relationships periodically to assess ongoing compliance
• Investigate any concerns raised regarding worker welfare or exploitation

Recruitment Practices

We shall:

• Ensure workers are engaged voluntarily and free from coercion
• Verify the identity of workers before placement
• Confirm right to work documentation where legally required
• Ensure workers understand the terms of engagement
• Prohibit the withholding of identity documents
• Promote transparent pay arrangements
• Ensure workers are free to terminate employment in accordance with contractual terms
• Encourage fair treatment and equal opportunities for all workers

Training and Awareness

We shall:

• Provide appropriate training and guidance to employees involved in recruitment, onboarding and compliance activities
• Raise awareness of the indicators and risks associated with modern slavery
• Promote understanding of reporting procedures and escalation processes
• Ensure management personnel understand their responsibilities under this Policy

Reporting Concerns

We encourage employees, workers, candidates, clients and suppliers to report any concerns relating to:

• Forced labour
• Human trafficking
• Worker exploitation
• Debt bondage
• Coercion or intimidation
• Unlawful deductions
• Retention of personal documents
• Any other activity inconsistent with this Policy

Concerns should be reported directly to the Managing Director or a designated member of management.

Reports will be treated seriously and investigated appropriately.

Whistleblowing Protection

We are committed to maintaining a culture of openness and accountability.

Individuals who raise genuine concerns in good faith shall be protected from retaliation, victimisation or adverse treatment.

All reports will be handled confidentially wherever possible and in accordance with our internal procedures.

Corrective Action

Where modern slavery or human trafficking concerns are identified, we shall:

• Investigate the matter promptly
• Take appropriate corrective action
• Notify relevant authorities where required
• Suspend or terminate relationships with non-compliant suppliers or contractors where appropriate
• Implement measures designed to prevent recurrence

Policy Review

This Policy shall be reviewed periodically to ensure continued compliance with legislation, industry standards and best practice.

The above processes are designed to:

• Prevent modern slavery and human trafficking within our business and supply chains
• Promote ethical recruitment and employment practices
• Protect workers from exploitation and abuse
• Increase awareness and accountability throughout our organisation
• Support compliance with the Modern Slavery Act 2015 and related legislation