Modern Slavery Statement
This statement is made as part of Octopus Personnel’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Octopus Personnel Limited operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.
This statement is published in accordance with section 54 of the Act, and relates to the financial year September 2017 to September 2018. It was approved by the director on 28th September 2017.
1 Our Business
Octopus Personnel is a Limited company operating in the recruitment sector. We provide introduction services and supply temporary workers in the industrial and commercial sectors.
Octopus Personnel Limited is an independent business.
1.1 Who we work with
All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.]
The hiring companies that we work with are located in Dorset, Wiltshire and Somerset. The work-seekers and worker we supply live in Dorset, Wiltshire or Somerset.
1.2 Other relationships
As part of our business, we also work with the following organisations:
2 Our Policies
Octopus Personnel has a modern slavery policy available at www.octopuspersonnel.co.uk
In addition, Octopus Personnel has the following policies which incorporate ethical standards for our staff and our suppliers.
• Information Security and Data Protection Policy
• Equal Opportunities & Diversity Policy
• Customer Service Policy
2.1 Policy development and review
Octopus Personnel’s policies are established by our director, based on advice from HR professionals, industry best practice and legal advice, and in consultation with local businesses. We review our policies as needed to adapt to changes.
3 Our Processes for Managing Risk
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights and whistle-blowing.
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 require the businesses we work with to address modern slavery concerns in their policies.
• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
• We work with GLAA, ALP and REC in order to combat the risk of modern slavery and human trafficking.
Our staff are encouraged to bring any concerns they have to the attention of management.
4 Our Performance
As part of monitoring the performance of Octopus Personnel, we track the following general key performance indicators:
• All staff are trained on the due diligence procedures appropriate to high risk activity which could assist in identifying a case of modern slavery as detailed below.
• Octopus Personnel check the right to work documentation of employees to confirm legitimacy of their right to work in the UK. Relevant documents are inspected and photocopied and records are kept in line with the UK Home Office guidance. When appropriate, employees are trained to advise Immigration Enforcement of any issues with right to work documentation.
• We operate a policy whereby if a worker wants to be paid through a bank account which is not held in their name, then we obtain written permission from both the worker and the account holder before making payment into the bank account. We also receive ID from both parties.
• On an ongoing basis, responsibility lies with the Managing Director to ensure that our processes, training and our understanding of the issues involved in modern slavery are kept up to date.
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our director:
• the percentage of suppliers who sign up to an appropriate code and provide their own modern slavery statements
• 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 and discuss our indicators with suppliers, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.
5 Our Training
All of our staff receive training and support that is appropriate to their role. In particular:
• Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
As part of this, our staff are encouraged to discuss any concerns that they have.