Modern Slavery Act Transparency Statement

Policy Statement

Modern slavery is a heinous crime and a violation of fundamental human rights. It takes 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 to exploit them for personal or commercial gain. In the United Kingdom modern slavery is governed by the Modern Slavery Act 2015.

Salt Recruitment Group Limited (‘Salt’) 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. This includes ‘right to work’ document checks, contracts of employment and checks to ensure everyone employed is aged 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 (e.g. cycle to work scheme, subsidised gym membership).

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
– National Insurance Number or foreign equivalent
– 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, onboarding processes (including reward schemes) 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, David Korthals.

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 also 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 permitted them to do so. Our consultants keep in touch with the contractors regularly throughout 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 our client’s request, we would carry out reference checks to confirm their work history. Following relevant data protection laws, Salt would 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, David Korthals (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 the Policy

Training on this policy and the risks 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 for the 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 also responsible for ensuring all members of staff comply with this policy. This Modern Slavery Statement was approved by the Board of Directors on 16 April 2020.

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

Mark Godfrey
Finance & Operations Director

Last updated on 16 April 2020