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Modern Slavery Policy

1. Purpose and Scope

Talented People Solutions Commercial Limited is committed to preventing modern slavery and human trafficking in all its operations, including the recruitment, placement, and management of temporary and permanent staff. This policy outlines our commitment to ethical practices in line with the Modern Slavery Act 2015 and applies to:

  • Internal staff

  • Temporary workers and candidates

  • Clients and subcontractors

  • Suppliers and third-party service providers

We recognise that the recruitment sector is particularly vulnerable to exploitation and are dedicated to protecting the rights and welfare of all workers engaged through our services.

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2. Our Commitment

We have a zero-tolerance approach to modern slavery. Talented People is committed to:

  • Ensuring all individuals we engage are treated fairly, with dignity, and without exploitation.

  • Implementing and continuously improving procedures to identify, assess, and mitigate modern slavery risks.

  • Promoting transparency and accountability in our supply chains and recruitment practices.

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3. Our Business and Supply Chains

Talented People provides recruitment services across engineering, production, food processing, transport and service and maintenance. We place candidates in temporary, contract, and permanent roles, often working with umbrella companies, labour providers, and subcontractors.

We acknowledge the risk of exploitation, especially among migrant workers, low-paid roles, and complex supply chains.

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4. Policies and Controls

To safeguard against modern slavery, we have implemented the following:

  • Modern Slavery and Human Trafficking Policy (this document)

  • Recruitment and Vetting Policy: Ensures candidates are recruited lawfully, with identity, right to work, and employment history checks

  • Whistleblowing Policy: Protects and encourages employees, candidates, or third parties to report concerns confidentially

  • Code of Conduct: Requires staff to uphold human rights and treat all individuals with respect and integrity

  • Client Contracts: Include anti-slavery clauses and require clients to confirm ethical labour practices

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5. Due Diligence and Risk Management

We perform due diligence when engaging with new clients, candidates, and suppliers, including:

  • Verifying the identity and legal work status of all candidates

  • Assessing the risk of exploitation in roles and sectors

  • Monitoring umbrella companies and subcontractors for ethical practices

We also screen for red flags such as:

  • Groups of workers with identical contact details or bank accounts

  • Workers who appear under duress or controlled by others

  • Accommodation or transport provided by third parties under coercive terms

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6. Training and Awareness

We provide annual training to:

  • Recruiters and compliance staff on identifying and reporting modern slavery

  • Front-line employees on recognising signs of exploitation

  • Clients and partners, where appropriate, through awareness briefings

Training includes real-world case studies, legislation updates, and incident response protocols.

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7. Reporting and Whistleblowing

We encourage all stakeholders to report concerns of modern slavery without fear of retaliation. Reports can be made via:

  • Confidential email: [Insert address]

  • Anonymous hotline: [Insert number]

  • In person to a manager or compliance lead

Please ensure this is emailed to Sam Provis (Associate Director)

All reports are investigated thoroughly, and appropriate action is taken.

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8. Response and Remediation

In cases where modern slavery is suspected or confirmed:

  • We will take immediate steps to protect the individual(s) involved

  • Engage with the Gangmasters and Labour Abuse Authority (GLAA), police, or relevant authorities

  • Conduct a root cause investigation and review related policies and processes

  • Terminate relationships with any clients or suppliers found to be complicit

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9. Monitoring and Continuous Improvement

We assess our performance by:

  • Conducting annual modern slavery risk reviews

  • Auditing high-risk placements and supply partners

  • Tracking reports and investigations of ethical concerns

  • Updating training and procedures in line with regulatory changes

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10. Approval and Communication

This policy is approved by the Board of Directors and is reviewed annually. It is made available to all employees, candidates, and supply chain partners, and published on our website in accordance with Section 54 of the Modern Slavery Act 2015.

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