Modern Slavery Statement

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes Smart Solutions’ anti-slavery and human trafficking statement for the financial year 2021/22.

April 2021

A message from our CEO

Smart Solutions (Recruitment) Limited (SSR) is committed to acting ethically and with integrity in all its business dealings. As part of this commitment, we continue to develop and implement robust systems and controls to mitigate the risk of modern slavery anywhere within our business operations or supply chain.

We recognise that in order to fully deliver on this commitment, we must continue to strive for improvement in all our processes. In 2020/21 we faced an unprecedented time in relation to the Covid-19 global pandemic; it was therefore important that we considered the key impacts the pandemic had on Modern Slavery and the subsequent impact to our business, employees and supply chain. We have utilised our continued relationship with Slave Free Alliance and Hope for Justice to evaluate new impacts and relevant actions. The Slave-Free Alliance provides knowledge and resources to give businesses the tools they need to identify the risk of modern slavery within their organisations and then put in place appropriate control measures. We look forward to our continued work with Slave-Free Alliance and to further develop our existing internal processes.

All those with whom we do business are expected to follow the highest ethical principles.  At  SSR, we expect all our business partners, representatives and suppliers to have robust processes in place to eliminate the risk of modern slavery occurring in their organisations. This has resulted in strengthened internal due diligence and other processes designed to allow us to monitor and work closely with our supply chain partners to achieve this aim.

SSR’s commitment to combatting modern slavery is supported by its core values: –

  • Engaged
  • Innovative
  • Trusted
  • Integrated
  • Responsible
  • Passionate

Our new Modern Slavery Statement develops these themes and sets out SSR’s detailed and strong ambition to prevent modern slavery from occurring anywhere within our organisation or in our wider business relationships.

Robert Webb

Chief Executive Officer

Smart Solutions (Recruitment) Limited

 

Background

Smart Solutions (Recruitment) Limited (SSR) are a partnership driven outsourced labour solution, providing innovative workforce solutions for industries across the UK and Europe.

In order to deliver the highest level of expertise for our clients, the Smart Solutions Group is comprised of 5 different divisions, which each has sector specialists working hard to ensure the highest level of service: –

  • Environmental Support Services division which deals predominantly with managed service waste clients
  • Branch Network division which has the broadest range of specialisms and is similar to the high street recruitment model
  • Onsite Managed Service division which is another managed service specialism but within other sectors such as manufacturing, aerospace, automotive, etc.
  • European Operations which are our services across Europe which include Europe to UK migration, self-service within Poland and Romania and also management of recruitment into other European countries, i.e. Slovakia, Netherlands, Denmark, etc.

 

SSR has a vast presence across Europe with 73 onsite hubs, 7 UK branches, and 3 European locations.

 

The Modern Slavery Act 2015 was designed to tackle slavery in the UK.

Modern slavery is a criminal offence and can happen in various forms. The offence covers slavery, servitude, human trafficking and forced labour, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal gain.

Our Employees

Smart recognises that its industry and the industries it supplies are often targeted by Gangmasters seeking to exploit individuals for financial gain.

Our workforce consists of permanent and temporary employees who work alongside our clients and their respective workforce.

Smart works particularly closely with our clients and other business partners to ensure consistent approaches and collaboration on prevention activity.

 

Review of current action

Governance and overview

Delivery of modern slavery prevention practices at SSR is led by Jade Oliver-Morris, HR Director – Environmental Support Services. Overall responsibility sits with the Smart Solutions CEO, who receives regular progress reports, as does the Senior Management Team.

During Anti-Slavery Day 2021, SSR launched new IT reporting to allow us further ways to identify duplication of data amongst our workforce. We also educated our employees on ways in which the Covid-19 pandemic could impact modern slavery and appropriate steps to take locally. It is important for the business to recognise these occasions, to spread awareness and share good practice. We used social media to promote business action as well as contributing to the ‘Zero Tolerance’ campaign.

Partnering and collaboration

Achieving SSR’s commitment to ensure that modern slavery does not occur anywhere within its business operations or its supply chain requires internal drive and energy but also external expertise, knowledge and collaboration. SSR chose to partner with Hope for Justice and Slave Free Alliance at the earliest opportunity in the focus on anti-slavery practices.

Slave-Free Alliance is a business scheme, run by global charity “Hope for Justice”. Hope for Justice was founded in the UK in 2008 with the goals of preventing exploitation, rescuing victims, and restoring lives. Hope for Justice has since grown to become an international charity, working across four continents and running rescue programmes, aftercare facilities for vulnerable children and providing trauma care for victims of modern slavery.

Hope for Justice set up Slave-Free Alliance to work in collaboration with businesses to develop a proactive strategy that businesses and their supply chains can adopt to deal with the threat of modern slavery. The core objective of Slave-Free Alliance is to support businesses to work towards a slave-free organisation and supply chain. SSR have worked with Slave Free Alliance and Hope for Justice on a number of occasions to present on our organisation’s experiences and offer useful information and insight on how other organisations can do the same thing.

SSR are also members of/licenced by the following organisations: –

Gangmasters and Labour Abuse Authority (GLAA)

The GLAA works in partnership to protect vulnerable and exploited workers. They are a Non-Departmental Public Body (NDPB) governed by an independent board.

Their role is to protect vulnerable and exploited workers. Through intelligence, they investigate reports of worker exploitation and illegal activity such as human trafficking, forced labour and illegal labour provision.

They investigate all aspects of labour exploitation in England and Wales and also work with partner organisations such as the police, the National Crime Agency and other government law enforcement agencies to target, dismantle and disrupt serious and organised crime across the UK.

 

Stronger Together

Stronger Together is a multi-stakeholder business-led initiative aiming to reduce modern slavery particularly forced labour, labour trafficking and other hidden third-party exploitation of workers. They provide guidance, training, resources and a network for employers, labour providers, workers and their representatives to work together to reduce exploitation.

Stronger Together focus on creating advice that is practical, pragmatic and easy for any business, of any size to understand and use. Stronger Together launched in the UK in 2013 and have since grown to have a global reach, running projects and programmes in countries across the world.

Association of Labour Providers

Established in 2004 at the instigation of the UK government, ALP is a specialist trade association promoting responsible recruitment and good practice for organisations that supply the workforce to the food processing, agricultural and wider consumer goods supply chain.

The ALP influences government and regulatory policy and provides a range of very useful information and services to its members.

The ALP’s mission is for “UK labour provision to be recognised as a model of global good practice”.

 

Supply chains

Targeting modern slavery within SSR’s business operations is not enough. SSR is also committed to addressing the risk of modern slavery in its supply chain. SSR has made changes to its supplier management processes however we recognise that there is still more to do and we’ve therefor begun to put in place a multi-stage due diligence and compliance assessment process, which will cover both the procurement phase and the contract delivery phase.

Ultimately, SSR expects its partners to work with it openly to identify and combat modern slavery. SSR will only trade with those suppliers who fully comply with the Code of Conduct, or those who are taking verifiable steps towards compliance.

Policies

SSR commitment to raising the bar to combat the risks of modern slavery and human trafficking in every area of its business is also to be found in the following documents: –

  • Hidden Labour Exploitation Policy
  • Code of Conduct

SSR has a dedicated internal working group with a cross-section of skills and knowledge to drive the programme forward including IT, Finance, Operations and HR.

 

 

Training and awareness

Training is delivered to all permanent SSR employees during induction and is refreshed annually via e-learning.  Training includes how to spot the signs of Modern Slavery, escalation processes and emergency procedures. Employees who work in ‘high risk’ geographical areas, determined by field experts, receive advanced training. This encompasses insight into specific gangs, local intelligence and operations.

All temporary employees are trained during induction on how to spot the signs. An audit mechanism is also in place to ensure consistency and compliance.

Various marketing facilities are used to spread awareness amongst our workforce including posters, bathroom stall stickers, leaflets and contact cards. All marketing is translated into various languages and details contact information for Hope for Justice and Smart’s 24/7 Confidential Helpline.

For SSR’s supply chain partners, the ‘Supplier Guide to Modern Slavery’ is communicated during the evaluation process as part of requests for information. This document is being issued to all members of the supply chain through a bulk send out approach and then in subsequent tenders as necessary.

Remediation

SSR works with charity partners across the UK to support in placing victims of modern slavery back in to work. Victims may have worked through SSR previously and been re-located and provided with safe harbour or may have worked through other employers. Building relationships with such partners as The Jericho Foundation, enable SSR to provide the most appropriate service and work assignment to a victim in line with their rehabilitation programme. Where possible and where we have multi-site contracts, SSR will endeavour to place a victim with the same client if they so wish. Smart offer training for specific skill areas as well as English Language courses.

Reporting

SSR collates data on all suspect information including known associate information. Reports are run on a weekly basis against our personnel records to identify duplicates of bank account details and addresses. SSR also hold a database of blacklist information collated through work with Police forces and Hope for Justice. Weekly reports identify changes or additions to personnel records that match blacklist data. Full internal investigations are conducted on any data hit.

Next steps and targets

Throughout the coming year, SSR will be focussing on development of our anti-slavery process in relation to our external business partners and network.

We will continue to network with peers and external experts to share knowledge and experiences to understand what works well elsewhere and identify where further improvements can be made.

We will continue to work openly with suppliers and will develop further protocols which will allow us to assess any instances of non-compliance within the supply chain on a case-by-case basis and tailor any remedial action appropriately.

We will use the energy and commitment of our staff as we proceed on our journey. Employees who have had training strongly support our commitment to develop processes to prevent any instances of modern slavery in our organisation.

We will develop our awareness programme to ensure that all staff are aware of the signs of modern slavery and know what to do if they suspect that a colleague may be a victim.

Summary of action

Completed Action 2020/2021 To Complete 2021/2022
Broadened network of external partners to include Metropolitan Police New supplier monitoring and audit process implementation.
Contributed to Government and Industry Leading research. Further broaden scope of Modern Slavery prevention activity to Eastern Europe.
Collaborated with a broader network of organisations and represented the Labour Providers on targeted cross-industry panels/forums. Install Hope for Justice Freedom Wall to recognise the victims we support and continue to fundraise.
Enhanced automated IT reporting to encompass additional indicators Creation of a Modern Slavery Standard along with Employee and Manager Guide.
Contributed to industry specific initiatives Implementation of a flexible employee probation period in order to create a legitimate opportunity to assess for modern slavery indicators on a one-to-one basis.
Implemented data collation and reporting of rehabilitation output Creation of a multi-sector Abolition Group.
Alignment to upcoming legislation changes.

 

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015 and constitutes the Smart Solutions (Recruitment) Limited’s Modern Slavery Statement for the financial year 2021/2022.

The statement was approved by the Smart Solutions (Recruitment) Limited CEO on 15 March 2021.

Robert Webb

Chief Executive Officer

Smart Solutions (Recruitment) Limited