Modern Slavery Statement for Financial Year 2019/2020

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and outlines the steps implemented and continually reviewed by the Virtual Human Resources group of companies (VHR) to prevent modern slavery and human trafficking within our business and supply chain. VHR has a zero-tolerance approach to any form of modern slavery, which encompasses slavery, servitude, human trafficking and forced labour. We are committed to understanding modern slavery risks and performing ethical recruitment practices, and we act with integrity and transparency in all business dealings. Our robust systems and stringent controls are designed to safeguard against the occurrence of any form of modern slavery within our business or our supply chain.

Our Policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

1. Anti-Slavery Policy.
2. Supplier Code of Conduct
3. Employer Code of Conduct

Anti-Slavery Policy

Our Business

VHR is a global technical recruitment consultancy providing staffing solutions to the Aerospace & Aviation, F1 & Automotive, Engineering & Defence and Marine industries around the world.

Our four global offices operate from London, Manchester, the Czech Republic and Abu Dhabi to work with businesses and individuals based across the globe. We work with a variety of internationally-based suppliers including second tier suppliers sourcing labour from countries including the Philippines, India, Nepal, Malaysia, Kenya and the Czech Republic performing services, which include search and selection of specialist labour.

Our High-Risk Areas

Physical labour in countries with low guarantee of enforcement of worker’s rights present a high risk of the existence of modern slavery. Our dedicated approach to these categories involves defining and regularly reviewing our definitions of high risk countries, ensuring compliance with local laws and certifying that each worker receives protection and fair pay. For such high-risk places, we perform additional research into local labour laws and each client company, and communicate closely with clients to ensure the implementation of appropriate measures upon instances of modern slavery. To protect all candidates, VHR verifies the backgrounds of each contractor worker and establishes desire to and capabilities to perform the requirements of each of our vacancies before placement.

Our proactive approach to ethical business and supplier relationships includes:

• - Assessing the country and its laws to verify sufficient safeguards on preventing modern slavery.
• - An anonymous review of the workplace.
• - Sending a trained VHR professional to investigate the worksites and working conditions of our clients in Europe on average every six months. Contractor interviews inform an anonymous survey and subsequent report to track ethical standards each year.
• - We provide whistleblower protocols and HR details to all contractors to empower anonymous candidate complaints.
• - Our trained VHR professionals assesses business relations and complaints of potential clients, which becomes a pivotal factor in VHR’s decision to conduct an ethical and profitable business relationship.
• - VHR provides clients with additional information and guidelines to identify issues in their own supply chains and encourage clients to act.
•  

Supplier Code of Conduct

Our Suppliers

VHR operates a supplier Code Of Conduct Policy and maintains a preferred supplier list consisting of supplier organisations that are regularly reviewed against stringent criteria. We conduct due diligence on all suppliers in terms of both financial and corporate responsibilities, including an online search to ensure that each organisation has never been convicted of modern slavery offenses, before appointing a preferred supplier. Our anti-slavery policy is included in all supplier contracts, with each supplier required to confirm that no part of their business operations contradicts this policy.

In addition to the above, our contracts require that suppliers confirm to us that:

1. The supplier organisations have issued own policies on eradicating modern slavery within their business
2. (For UK based suppliers) The supplier organisations pay their employees at least the national minimum wage / national living wage (as appropriate)
3. (For international suppliers) The supplier organisations pay their employees any prevailing minimum wage applicable within their country of operations
4. Whether the supplier organisations desire to opt-out from VHR’s Anti Modern Slavery Framework clauses Our Performance Indicators

Our process of identifying and responding to Performance Indicators ensure our checks are fit for purpose in uncovering the existence of modern slavery and sufficiently protecting workers upon occurrences.

We detect anomalous patterns during our recruitment cycle, e.g. if the worker received early termination or reduced wages upon contract extensions, and imminently communicate our concerns to the client. The effectiveness of our actions to prevent human slavery and/or trafficking within our business or supply chain will be evidenced by the following indicators:

• During, by the end of the contract or reasonable time after the end of contract, there have been no complaints discovered through anonymous questionnaire
• There have been no sudden or unreasonable reductions in contractor’s wages which could be presumed to be stemming from coercion/ deception.

Upon detection of modern slavery practises we issue recommendations to suppliers and, where necessary, work with supplier businesses to ensure full compliance with the legislation.

Employer Code of Conduct

We promote a sophisticated whistleblowing policy across all our offices to detect and deal with any signs of modern slavery. This ensures that any staff member with concerns can raise issues and receive appropriate assistance confidentially. We endorse awareness and recognition of modern slavery practices to our employees and embed our values as an ethical recruitment business into our internal communication strategy. Induction trainings involve a mandatory instruction on recognition of modern slavery in working environments. We promote related webinars for the entire workforce and provide special guidelines for all the client facing departments at VHR, who are the first point of client contact, with updates on modern slavery legislation communicated to the workforce via email. We offer online and physical copies of guidelines and booklets to each member of staff, aimed at raising awareness and equipping our employees to act upon encounters of breaches to modern slavery framework.

This statement was approved by the Board of Directors on 30 September 2017.