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Modern Slavery Statement

This statement is made as part of Approach Personnel Limited’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It sets out the Companies’ actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
Approach Personnel Limited recognises that it has a responsibility to take a robust approach to slavery and human trafficking. We all have a responsibility to be alert to the risks, however small, within our own business and in the wider supply chain.
Our staff are expected to report concerns and management are expected to act upon any reports.

OUR BUSINESS
Approach Personnel Limited is a independently owned, Limited company operating in the recruitment sector. We supply temporary and permanent workers in the construction, engineering, and meat processing sectors. 
Our offices are based in Nottingham and all of our labour is supplied within the United Kingdom.

OUR SUPPLY CHAIN
Our supply chain includes the sourcing & provision of labour for temporary assignments to the recruitment industry for use on projects and assignments.

OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. 
Our Modern-Slavery policy reflects Approach Personnels commitment to always act ethically and with integrity throughout our business relationships.
We have developed robust systems and procedures to test for the presence of Slavery and/or Human Trafficking whilst providing clear guidance to all of our teams on how to alert management to any suspected incidents.

DUE DILIGENCE FOR SLAVERY AND HUMAN TRAFFICKING
As part of our policy and procedures to identify any risk, Approach Personnel ensures that;

  • Where viable, we run regular Assignment Checks to ensure that workers hours and pay are accurate and that their working environment matches our requirements.

  • We always complete a Right to Work check, ensuring that those workers do have the right to work in the UK and are aware of the rights and responsibilities working in the UK gives.

  • Where possible we speak with payroll partners to ensure that the worker is provided with adequate support throughout their assignment.

  • We aim to always build long standing relationships with suppliers and clients and always make clear our expectations regarding the business behaviour.

  • We will also aim to work with suppliers that are members of their appropriate trade association.

  • Whistleblowing Policy; the organisation encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of the organisation.

An annual audit comprising of questions regarding the management of combating Modern Slavery throughout the supply chain, seeking confirmations, and evidencing compliance.

​​​​​​​RISK ASSESSMENT

We have completed a comprehensive risk assessment of our direct and indirect supply chain. We have been identified as “low risk”.
In order to assess the risk of modern slavery, we use the following processes with our suppliers:

  • We review the potential for risk at regular intervals, including the possibility of re- auditing a supplier or conducting spot checks.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems. 
Additionally, we have taken the following steps to minimise the possibility of any problems:

  • We reserve the right to conduct spot-checks of the businesses who supply us, to investigate any complaints.

  • We collaborate with our suppliers to improve standards and transparency across our supply chain.

Our staff are encouraged to bring any concerns they have to the attention of management.

SUPPLIER ADHERENCE
We have a zero tolerance to slavery and human trafficking. We expect all those in our supply chain and any contractors to comply with the values set out in this document.

TRAINING
To guarantee a high level of understanding and engagement with this policy and the risks associated with modern slavery and human trafficking in our supply chain or business, we provide training to relevant members of staff.
All Directors have been briefed on this subject. 

MEASURING EFFECTIVENESS IN COMBATTING SLAVERY AND HUMAN TRAFFICING
Based on the potential risks we have identified, we have established the following key performance indicators, which are regularly assessed by our board of directors and our senior management team:

  • the effectiveness of enforcement against suppliers who breach policies.

  • the amount of time spent on audits, re-audits, spot checks, and related due diligence.

  • the level of modern slavery training and awareness amongst our staff.

We benchmark our indicators against industry best-practice, to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

POLICY DEVELOPMENT AND REVIEW
Approach Personnel Limited’s policies are established by our directors and our senior management team, based on advice from HR professionals, industry best practice and legal advice. We review our policies annually or as needed to adapt to changes.

DECLARATION
This statement has been approved by the organisation’s board of directors and is made in pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the businesses slavery and human trafficking statement.