Modern Slavery & Human Trafficking Policy

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It can take 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 other to exploit them for personal or commercial gain.

Fair Pay Services is committed to ensuring that its staff and any workers it supplies are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and/or similar human rights abuses. We are also committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. 

This statement sets out Fair Pay Services’ actions to understand all potential modern slavery risks related to the business and to ensure steps are maintained to prevent both slavery and human trafficking.

Our Business and Supply Chain

Fair Pay Services is an umbrella company which operates in line with HMRCs understanding and definition of an umbrella provider. Our work involves employing and supplying temporary workers to one or more recruitment agencies who are responsible for finding suitable temporary assignment(s) for those workers with an end client. 

An overarching contract of employment is given to all employees which includes the right to earn at least National Minimum Wage for all hours worked. We also give further employment protections such as holiday pay, statutory rights, and other such benefits and will comply with our legal obligations to ensure the health and safety of all our employees and workers.

As part of the temporary work industry, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and to be alert to the risks, however small, in our business and in all the business in our supply chain.

At the time of writing our supply chain consists of over 30 recruitment agencies of which terms of business are in place for each. We ensure that we only work with reputable recruitment agencies when placing workers and ensure that relevant documentation is in place and that the workers have a full understanding of the requirements of the assignment before accepting it.

Our Process for Managing Risk

In order to assess the risk of modern slavery, we use the following processes:

  • Identify and assess potential risk areas when engaging with new agencies
  • Review the potential for risk at regular intervals
  • Protect whistleblowers,

We have reviewed our policies and procedures to assess their effectiveness in identifying and tackling modern slavery. We have in place systems to:

  • Verify a worker’s ID and right to work
  • Ensure our workers operate under a permanent contract of employment with guaranteed income levels, such as National Minimum Wage
  • Provide statutory worker rights and pay to all our employees.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is also the responsibility of those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy and must notify their manager as soon as possible if they believe of suspect a breach of this policy has occurred.

Identified Risks

After due consideration we believe that we are in a low-risk position and are confident that there is no slavery or human trafficking taking place directly within our organisations or in the supply chains we work in. However, we continue to be alert to the potential for problems.

Although we employ some workers that are low paid and low skilled, we believe that our processes will highlight any case where our workers may be at risk.

Policy Compliance

Any employee who breaches this 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 breach this policy.

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