Written by Sam

MODERN SLAVERY

Introduction from Sam Sanderson, Managing Director, Recruitment Panda Ltd

Recruitment Panda Ltd are a Recruitment Consultancy who source candidates for employment with a variety of client employers in a growing range of sectors that started with the health and social care sector. We are therefore fully committed to preventing acts of modern slavery and human trafficking from occurring within the business and our supply chain. 

Our Employee and Supplier Code of Conduct make clear that we expect our own people, and everyone employed by our Clients, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice. 

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year. 

Sam Sanderson 

Managing Director 

18th May 2022 

 

RECRUITMENT PANDA STRUCTURE 

We are a UK based specialist recruitment consultancy. Our parent company is Recruitment Panda Ltd. Directors Sam and Ian Sanderson employ a total of 11 staff, who are Recruitment Consultants and/or Administrators. 

The Company delivers permanent recruitment services and solutions throughout the UK. The Company is organised into the following divisions:  

• South East and Home Counties 

• South West and Midlands 

• Wales, the North of England and Scotland 

 Each of which is subdivided into various regions with several specialist consultants for the sector specialist brands we now operate: 

• Health & Social Care 

• Business Support - HR, Finance & Accountancy 

• IT & tech - Software Engineers with a wide range of specialisms 

• Construction - Quantity Surveyors, Project Managers, Architects 

• Executive - Senior & Executive Management 

 Selectively recruiting exclusively for employers who care. 

 

OUR SUPPLY CHAIN

As a provider of recruitment services, we consider our supply chain to be relatively low risk in comparison to many other industries. 

Our supply chains include, but are not limited to, sourcing candidates for clients and the maintenance of our office facilities. These involve the use of a variety of high-tech online and offline technologies including www.recruitmentpanda.com which is wholly owned, developed and hosted in-house, along with 3rd party technologies such as Adobe DC, Microsoft Office and Google Workspace used in the onward supply of candidates to our clients. 

We expect our suppliers and potential suppliers to aim for high ethical standards and to operate in an ethical, legally compliant and professional manner by adhering to our Supplier Code of Conduct. We also expect our suppliers to promote similar standards in their own supply chain. 

 

RISK AND COMPLIANCE 

Recruitment Panda Ltd has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain.  As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in particularly high-risk sectors. That said, when appraising our supply chain, a risk-based approach has been developed, focussing on: 

• Products we buy that are imported from countries identified as having a high risk of Modern Slavery; and 

• Services we consume across industries where Modern Slavery is typically more prevalent. 

In terms of the products we buy, the Group has referred to the Global Slavery Index’s list of products with identified risk of forced labour by source countries. The only risk area identified relevant to Recruitment Panda Ltd was in relation to Electronics - Laptops, computers and mobile phones. 

Recruitment Panda Ltd, like with many other corporate organisations, consumes products in these areas from globally recognised firms who we require to have established Modern Slavery policies and practices in place, and we will continue to monitor their activities. 

In terms of the services we consume, our risk assessments have determined that Cleaning and recycling/waste disposal services represents the only service line which carries a higher risk of Modern Slavery. This evaluation process across both categories continues on an annual basis. 

 

Our Policy on Modern Slavery and Human Trafficking 

Our Employees are required to comply with our Employee Code of Conduct and our Suppliers with our Supplier Code of Conduct. These policies reflect our commitment to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our business and UK supply chain. 

 

Due Diligence Processes for Slavery and Human Trafficking 

Our Own Business 

Recruitment Panda Ltd prohibits the use of all forms of forced labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws. 

As part of our own business, we supply permanent personnel to a number of clients. We take our obligations seriously in this respect and have well established procedures to ensure that those workers are protected from the risks of modern slavery. We ensure that temporary workers: 

• Have the right to work the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately. 

• Take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake. 

• We carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights. 

• Where we are responsible for such personnel while they are on assignment on our client’s premises, they are  always free to leave their assignment; and 

• Receive compliant pay as determined by the Agency Workers Regulations 2011. 

In addition, all our employees, through the Employee Code of Conduct, are made aware of Recruitment Panda’s requirement for employees to support and uphold human rights principles and know that Recruitment Panda will not tolerate, engage in or support the use of forced labour. 

 

Our Supply Chain 

We include due diligence queries in UK RFP processes to identify our potential suppliers’ approach to modern slavery and these assist in our determination of whether the supplier should be considered a high-risk supplier. A high-risk supplier is sent a questionnaire so we can further assess their approach to the issue of modern slavery. 

Supplier contracts contain anti-modern slavery clauses which place an obligation on suppliers to comply with the Modern Slavery Act 2015 and rights of audit to help us identify unethical practices.  If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would terminate our relationship should we see no improvement in the way their business is conducted. 

This approach is designed to: 

• Identify and assess potential risk areas in our UK supply chain. 

• Mitigate the risk of slavery and human trafficking occurring in the supply chain. 

• Monitor potential risk areas in the supply chain; and 

• Provide adequate protection to whistleblowers. 

In the last 12 months we engaged with our UK high-risk suppliers to ensure a Modern Slavery questionnaire was completed to gain further assurance on their compliance and maturity. The questionnaire posed questions across a number of key areas, including (but not limited to): 

• Human trafficking 

• Auditing 

• Whistleblowing 

• Breach monitoring 

Responses have been reviewed and the outcome was that we are satisfied that to date we actually have zero high risk suppliers, although we will, as a matter of best practice, continue to keep monitoring the modern slavery compliance of all our suppliers.  The Company’s Board has now set out a series of modern slavery KPIs for monitoring. Thus far, KPIs revealed no cause for further investigation. 

 

FURTHER STEPS 

Following a review of the effectiveness of the steps taken in the previous financial year. To prevent modern slavery or human trafficking occurring in our business, we intend to take the following further steps during the course of the 2023 financial year: 

• We will continue to operate the following KPIs: number of upheld complaints (we have a zero-tolerance approach) and in respect of high-risk suppliers providing services to our UK business, 100% of tier 1 suppliers mapped and risk assessed and 100% engagement and/or audits carried out regarding modern slavery compliance; and

• In addition to the ongoing monitoring, we intend to on-board UK medium risk suppliers to the modern slavery assurance programme of which we presently identify none.  

In accordance with the risk-based approach developed in the UK, the focus for regions and their respective supply chains will continue to be on: 

• Products we buy that are imported from countries identified as having a high risk of Modern Slavery; and

• Services we consume within countries across industries where Modern Slavery is typically more prevalent. 

 

Pursuant to section 54(1) of the Modern Slavery Act 2015 and the regulations made by the secretary of state, as a micro entity we are not legally, but in our view are ethically bound to make such a statement; and so the above is reviewed and adopted by the Board and constitutes our Group's slavery and human trafficking statement and also forms a part of our Supplier Code of Conduct for the financial year ending 31 May 2023. 

 

Sam Sanderson - Managing Director 

18 May 2022