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 2022/23.

April 2022

A message from our CEO

Smart Solutions (Recruitment) Limited 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 2022/23 we continued to face an unprecedented time in relation to the Covid-19 global pandemic and our recovery from it; it was therefore essential that we continued to consider the impact the pandemic had on Modern Slavery and our response to this through 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.  Slave-Free Alliance provides knowledge and resources to give us the tools we need to identify the risk of modern slavery and then put in place appropriate control measures. We look forward to continuing our work with Slave-Free Alliance and to further develop our existing internal processes as a result.

All those with whom we do business are expected to follow the highest ethical principles. Here at Smart, 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.

Smart’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 Smart’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 is 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 comprises of 4 Divisions, each with sector specialists working hard to ensure the highest level of service: –

  • Environmental Support Services division which deals predominantly with managed service waste and recycling clients
  • Smart Workforce Solutions Division including both Branch Network and Onsite Managed Services which has the broadest range of specialisms and is similar to the high street recruitment model
  • 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.

Smart Solutions has a significant presence across Europe with 78 onsite hubs, 6 UK branches, and 2 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 Smart 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 Week in October 2021, Smart launched its Hope for Justice “Freedom Wall” a tangible, visual symbol of its zero-tolerance approach to Modern Slavery as well as a primary source of fund raising for the charity.  We also continued to educate our employees on ways in which the Covid-19 pandemic was impacting modern slavery and appropriate steps to help us remain vigilant. It is important for the business to recognise these occasions, to spread awareness and share good practice. We also continued to use social media to promote business action as well as contributing to wider industry response to the threat.

Partnering and collaboration

Achieving Smart’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. Smart chose to partner with Hope for Justice and Slave Free Alliance at the earliest opportunity in its 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. Smart 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.

Smart 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 Smart’s business operations is not enough. Smart is also committed to addressing the risk of modern slavery in its supply chain. Smart has made changes to its supplier management processes, including the introduction of a Suppliers Code of Conduct in mid-2021 and a re-writing of its Supplier Evaluation Questionnaire, with specific detailed focus on anti-Modern Slavery practices designed to assist us in supporting and working closely with our supply chain partners to achieve this aim.

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

Policies

Smart’s 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
  • Supplier Code of Conduct

Smart 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 Smart 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 can encompass 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 techniques are used to spread awareness amongst our workforce including posters, bathroom stall stickers, leaflets and contact cards. A new campaign titled “use your voice – some can’t” was launched to coincide with Anti-Slavery Day in October 2021.  All marketing is translated into various languages and details contact information for Hope for Justice and Smart’s 24/7 Confidential Helpline.

For Smart’s supply chain partners, the ‘Supplier Guide to Modern Slavery’ is communicated during the evaluation process as part of requests for information. This document was updated in late 2021 and has been re-issued to all members of the supply chain with an explanatory covering letter.

Remediation

Smart works with charity partners across the UK to support in placing victims of modern slavery back in to work. Victims may have worked through Smart 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 Smart 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, Smart 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

Smart collates data on all suspect information including known associate information. Smart’s weekly reporting from its personnel database to identify duplicates of bank account details, addresses and next of kin information has been upgraded and anything suspicious is investigated and closed out. Smart also holds a database of information collated through work with Police forces and Hope for Justice. Weekly reports identify changes or additions to personnel records that match this data. Full internal investigations are conducted on any data hit.

Next steps and targets

Throughout the coming year, Smart will be focussing on post pandemic and post Brexit evolutions to the threat of Modern Slavery together with continuing 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 harness the energy and commitment of our staff as we proceed on our journey, including our newly appointed regional “Modern Slavery Champions” within the Environmental Support Services Division (ESS) who in addition to undergoing advanced training in Modern Slavery will act as the regional focus for our initiatives as well as a key information sharing network internally and with key clients. Employees who have had training strongly support our commitment to develop processes to prevent any instances of modern slavery in our organisation. Once the role is bedded into the organisation, opportunities for expanding the initiative into the other divisions are to be considered.

We will continue to 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 2021/2022 To Complete 2022/2023  
 Launched new anti-slavery publicity Campaign with the aim of increasing vigilance across all company and client work sites Continuation and evolution of supplier monitoring and auditing regarding modern slavery practices and compliance.  
 Developed and rolled out auditing of 2nd tier agency suppliers, utilising the expertise of Slave Free Alliance. Complete auditing of 2nd tier agency supply chain with support from SFA, including feeding back on areas where improvement is required.  
Collaborated with a broader network of organisations and represented the Labour Providers on targeted cross-industry panels/forums. Continuation of working with Hope for Justice as a key corporate partner by nominating them as one of our charity partners for 2022. This will further strengthen the engagement and development of staff involvement with the charity.  
Further enhanced automatic IT reporting to encompass additional indicators and follow up/close out where risk identified Creation of a Modern Slavery Standard along with Employee and Manager Guide.  
Contributed to industry specific initiatives – including creation of the IPHR Waste & Recycling Steering Group modern slavery tool kit Creation with Biffa of a multi-sector Abolition Group in the Midlands.  
 Launched Smart Solutions’ Hope for Justice “Freedom Wall” in Ashby Office.  Embed the role of “Modern Slavery Champions” as key source of knowledge and networking on Modern Slavery wherever relevant in the wider Smart Solutions Group.  
Launched new Supplier Code of Conduct and revamped Supplier Evaluation Questionnaire  Further develop the audit programme to include welfare interviews and checking of access to bank accounts during a live audit programme, etc.  
Launched regional “Modern Slavery Champions” as focus of activity in operations  
Developed the Modern Slavery audit programme to include flexible worker training as a ‘major’ to highlight the importance to all staff.  

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 2022/2023.

The statement was approved by the Smart Solutions (Recruitment) Limited CEO on 30th March 2022.

Robert Webb

Chief Executive Officer

Smart Solutions (Recruitment) Limited