Modern Slavery Act Policy


Modern slavery in all its forms of slavery and servitude, forced or compulsory labour and human trafficking is a shocking crime and will not be tolerated within our business or our supplier's chain.

Our Business

We will take appropriate steps to ensure everyone who works for us has their fundamental human rights respected and anyone we do business with upholds these principles.

This statement details policies, processes and actions we have taken to ensure that slavery and human trafficking do not take place in our supply chains or our business.

Our Purpose

We want to be a truly responsible business and create better outcomes for:

▪ Our people | by providing an environment in which they can thrive and develop.

▪ Our clients and candidates | by being focused on delighting them, both now and in the future.

▪ Our suppliers and partners | by treating them fairly and encouraging them to deliver.

▪ Society | by acting as a responsible business for the communities we serve.

To deliver our purpose successfully, our values: authentic, innovation, loyal and compassionate and associated behaviours must guide all our decisions and actions, each and every day.

Our People

We are people-focused who have a deep understanding of our clients’ markets and needs to

create value and better outcomes for all our people in how we design, implement and operate

essential services; develop and sell specialist software to support critical business functions; and support the people and communities we serve.

▪ We ensure we have a fair and inclusive workplace, where our people are valued, their differences are respected, and discrimination is eliminated.

▪ We recruit and treat employees fairly, our human resources (HR) policies set out our procedures on how we:

▪ Recruit and select employees in a fair, lawful and professional manner, both for internal and external candidates.

▪ We treat all employees fairly during their employment and have in place procedures to raise a grievance or a involve local trade union, where they exist, or where this is a legal requirement to do so if an employee feels they have been treated unfairly.

▪ Manage the exit of an employee in a fair and consistent manner.

Working conditions

We provide fair working conditions for all our employees including terms and conditions of employment, remuneration, working hours, health and safety, resting time, holiday entitlements and benefits. These are applied according to territory-specific statutory requirements. The key principles are that:

▪ Our employees’ pay will not be lower than that required by the National Minimum Wage

▪ Hours of work will be in line with the Working Time Directive

o Employees shall not be contractually required to work more than 40 hours per week and overtime will only be worked on an optional basis. Forced or compulsory work is prohibited.

o Employees will not be forced into involuntary labour and coercion at work is not


o Financial penalty as a disciplinary sanction is prohibited.

All employees can raise concerns (‘blow the whistle’) through our Speak Up Policy, including

Concerns about slavery and human trafficking. This Speak Up Policy sets out the channels available to any person who works for, or with, us and employees can raise these concerns openly and at any time in confidence.

We also seek feedback from employees through regular surveys where we gauge how our people feel about working for us. This helps leaders and HR identify potential issues around a culture that could lead to a failure of ethics, controls or governance before they occur.

Our Supply Chain

We value our business relationships and seek to build lasting relationships, treating our suppliers fairly and paying promptly.

We want to work with suppliers who share our values and support us to create better outcomes. We are working with our supply chain to ensure that together we can achieve wider social, economic and environmental benefits.

As a minimum, we expect both ourselves and our suppliers to comply with all regulations providing safe working conditions, treating workers with dignity and respect, acting fairly and ethically and being environmentally responsible where practicable.

To make employees aware of the Act and the drivers of modern slavery, this statement is shared with all employees through our internal communication channels. It is also available on our website.

Board approval

This statement is made pursuant to section 54(1) of the Act, has been approved by the Board of Directors, and will be updated annually in line with the Modern Slavery Act’s reporting requirements.

For more information, please visit

Date reviewed: June 2020