This statement and policy relates to ADVANCE Contracting Solutions Ltd but the principles laid out are observed by all companies within the ADVANCE Group in accordance with section 54 of the Modern Slavery Act 2015.
This is ADVANCE Contracting Solutions Ltd anti-slavery and human trafficking statement and policy issued under the Modern Slavery Act 2015 and builds upon the statement from 2022.
Modern slavery is a 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 in order to exploit them for personal or commercial gain.
At ADVANCE we have a zero-tolerance approach to any form of modern slavery, and we fully support measures by law enforcement agencies to eliminate all forms of this criminal activity. We are committed to acting ethically and with integrity in all our business dealings and relationships, as well as by putting effective systems, processes, and controls in place, to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We expect the same high standards from all our contractors, clients, suppliers, and other business partners.
We establish a relationship of trust and integrity with all our contractors, clients, suppliers, and business partners, and our selection and on-boarding procedures include high levels of due diligence and compliance checks.
In all our business dealings and processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our contractors, clients, suppliers, and business partners will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
ADVANCE offer employment, accountancy and subcontracting solutions to contractors who undertake temporary assignments with recruitment businesses. We support contractors & recruitment businesses in a wide range of sectors and industries throughout the UK.
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
ADVANCE's HR Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and processes to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to the HR Manager via the contact page of our website.
You must ensure that you read, understand and comply with this anti-slavery policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.
You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
You are also encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager as soon as possible.
You should note that where appropriate, and with the welfare and safety of workers as a priority, we give support and guidance to our contractors, clients, suppliers and business partners to help them address coercive, abusive and exploitative work practices in their own business, working environment and supply chains.
If you are unsure about whether a particular act, the treatment of workers, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats, or any other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR Manager immediately.
If the matter is not rectified, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Staff handbook, and is available upon request.
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided accordingly.
Our zero-tolerance approach to modern slavery must be communicated to all contractors, clients, suppliers, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
The following policies are available upon request to all staff throughout the ADVANCE Group:
These policies set out the standards we expect of staff and include details of the procedures in place that can be followed to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and/or organisations working on our behalf if they breach this policy.
Due diligence is an essential practice for ADVANCE, we consistently monitor our contractors, clients, suppliers and business partner cash flow, assets, insurance policies and third-party suppliers, and are taking all necessary measures to identify, prevent and mitigate incidences of modern slavery in our operations and supply chains.
ADVANCE seeks to assess and manage all risks of modern slavery within the workplace.
Here are some of the steps ADVANCE has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.
During our onboarding process, all workers and contractors are subject to our robust due diligence and compliance checks. These processes include checking all personal details, such as address and bank details, as well as verifying right to work documentation, such as passports. These are essential compliance processes but are also considered as potential indicators of modern slavery that may require further review.
ADVANCE’s systems identify if two or more workers are sharing the same home address, and this is checked weekly by ADVANCE’s Compliance team.
Verifying documentation highlights any workers or contractors unwilling to provide that information. For example, an instance of a worker at risk could be if they have had their personal belongings or identification taken from them – or if other documents are being withheld.
In line with the Home Office guidelines, in the Autumn of 2022, ADVANCE integrated with an Identity Service Provider (IDSP) to utilise Identification Document Validation Technology to carry out digital Right to Work checks which has enhanced the security and integrity of the checks that we conduct. The process requires the perspective employee to capture a live photograph of their Right to Work and take a live ‘selfie’ which, by using the Identification Document Validation Technology, confirms that the individual who is in the ‘selfie’ is also the individual in the Right to Work document. This gives ADVANCE comfort that the perspective employee must have personal access to their Right to Work documents.
An individual who does not have their own bank account or, is sharing a bank account with somebody else, is recognised as a potential victim of modern slavery and may need further checking.
ADVANCE’s systems also identify if two or more workers are sharing the same bank account details, and this is checked weekly by ADVANCE's Compliance team.
Injuries, fatigue or poor physical health and hygiene are also recognised as potential indicators of modern slavery that may need further checking.
In addition, ADVANCE’s systems identify if an individual is regularly completing an excessive number of hours work, and this is checked weekly by ADVANCE’s Payroll team.
In accordance with The Modern Slavery Act 2015, preventing a worker from being paid the National Living Wage/National Minimum wage, could also be recognised as an act of modern slavery. ADVANCE ensure that all its employees are paid at least the National Living Wage/National Minimum Wage and, prior to completing payments, ADVANCE’s payroll team run specific reports to check this daily.
During our onboarding process for new clients, background checks are completed by ADVANCE’s Compliance Team in order to identify if any unusual business activity or previous affiliation with suspected instances of Modern Slavery are associated with the client.
Anyone who thinks they may have come across an instance of modern slavery, or indeed who may be a victim themselves, can call the Modern Slavery Helpline on 0800 0121 700 for more information and guidance on what to do next.
This statement is made in accordance with section 54 of the Modern Slavery Act 2015 and forms the ADVANCE Group’s slavery and human trafficking statement. The statement has been approved by the Managing Director.
Published 03 April 2023