Modern Slavery Act Transparency Statement

Policy statement

We take our responsibility to combat modern slavery seriously and are committed to ensuring that our operations and supply chains are free from any form of forced labor or exploitation.

In line with the updated guidance published by the UK government in September 2021, we have reviewed and updated our Modern Slavery Statement to provide more detailed information on our due diligence measures and remediation actions.

Our statement includes information on our structure and supply chains, policies and procedures for identifying and addressing modern slavery risks, and any remediation actions taken to address such risks.

We are committed to maintaining the highest standards of transparency and accountability and will continue to review and update our Modern Slavery Statement annually to reflect any changes in our operations or supply chains. Modern slavery is a heinous crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced, child and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. In the United Kingdom modern slavery is governed by the Modern Slavery Act 2015.

The Salt Group is committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce policies to ensure modern slavery is not taking place anywhere in our own business or our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners.

In accordance with the Modern Slavery Act 2015, Salt has prepared a Modern Slavery Act Transparency Statement.

Employment at Salt

Salt has robust recruitment processes in line with UK employment laws, including: ‘right to work’ document checks, contracts of employment and checks to ensure everyone employed is 16 and above. Furthermore, we pay market salaries and rewards are reviewed annually. We also support initiatives to support our staff member’s physical and mental wellbeing and lifestyle choices.

Supply chains

Our teams are specialists in every aspect of digital recruitment. Although Salt does not supply workers in the care, construction or manufacturing industry we accept that no part of our business is immune to the risk of modern slavery. We appreciate that some parts of our business and their respective supply chains might have a higher risk of modern slavery taking place.

As part of our comprehensive Contractor Onboarding Policy, Salt has extensive due diligence processes in place to combat any illegal practices related to slavery and human trafficking in our business and supply chains. For the placement of temporary contractors, Salt only works with vetted companies (Personal Service Companies) and would typically ask for the following documents:

– CV
– Right to work/ID
– Age verification through Right to Work document
– Bank Statement
– VAT certificates and/ or tax certificates
– Insurance certificates
– References (when requested by our clients)
– Other documents when required by our clients/ local laws

Furthermore, Salt undertakes extensive due diligence when working with management companies (also called: umbrella companies) by verifying their company structure, their on boarding process (including reward scheme) and their compliance with local laws. Salt has an Approved Supplier List in place as it prefers to work with only the most compliant and professional umbrella companies in the market. This Approved Supplier List is evaluated on an annual basis by our Head of Compliance & Contractor Management.

Furthermore as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour and we expect that our suppliers will hold their own suppliers accountable to comply with the same standards. Please note that our suppliers are not entitled to subcontract their services unless Salt and our clients have given them permission to do so. Our
consultants furthermore stay in touch with the contractors on a regular basis throughout the duration of their assignment to resolve any issues the contractor may have (for example not getting paid by their company).

For candidates who are considered for permanent employment with our clients, we only introduce candidates to our clients if we have received their CV and a confirmation that the applicant has the right to work in the relevant territory. Upon the client’s request we would furthermore carry out reference checks to evidence work history. In accordance with relevant data protection laws Salt would
furthermore only introduce the candidate to our client if they have given their explicit consent to do so.

Compliance with the policy

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for Salt or under our control. If you believe that any act of modern slavery has occurred, or may occur in the future, please contact the Head of Compliance & Contractor
Management (contract@welovesalt.com) without delay. If a specific case of modern slavery is identified in the United Kingdom it should also be reported to the police immediately on 101. If potential victims are in immediate danger the standard 999 emergency number should be used.

Communication and awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed. Our zero-tolerance approach to modern slavery is reinforced as appropriate.

Breaches of this policy

Salt reserves the right to terminate existing agreements with organisations if they act in violation of the Modern Slavery Act.

Responsibility of this policy

The Head of Compliance & Contractor Management (contract@welovesalt.com) has responsibility for keeping this policy up-to-date and monitoring its use and effectiveness and auditing existing policies to ensure they are effective in countering modern slavery and human trafficking. Management at all levels are furthermore responsible for ensuring all members of staff comply with this policy

Signed for and on behalf of Salt Recruitment Group Limited and its subsidiary companies.

Raquel Ireland – Head of Compliance

Last updated on: 30 Jan 2024