Modern Slavery Statement

Real Recruits Consulting Limited have a zero tolerance to modern slavery. Real Recruits Consulting Limited commits to developing and adopting a proactive approach to tackling hidden labour exploitation throughout the supply chain in which it operates. The following statement focuses on complying with the Modern Slavery Act (2015) ensuring visibility on the steps Real Recruits Consulting Limited take in removing modern slavery in our supply chain. Modern Slavery is the act of depriving an individual of their liberty for financial gain. This can include Forced Labour, Human Trafficking, Wage Theft, Work Finding Fees or Bribes and Rogue Landlords. Real Recruits Consulting Limited aim to eliminate all forms of Modern Slavery within our supply chain with the use of company policies, training and working with regulatory bodies such as GLAA.

Our Policies

Real Recruits Consulting Limited are committed in implementing effective strategies and procedures in removing Modern Slavery from our supply chain. One way we enforce this is through our Hidden Labour Exploitation Policy. Real Recruits Consulting Limited prides itself on trading ethically within the market; the following group policies shape the companies practices in ensuring ethical business:

• Ethical Policy
• Anti–Bribery Policy
• Equal Opportunities, Trust, Dignity & Respect Policy
• Working Young People Policy
• Temporary Workers; conduct Regulations and Working Time
• Environmental, Corporate & Social Responsibility Policy

Our board of Directors ensure all company policies are upheld by every member of staff and comply with our ethical and legal obligations. These company policies are available from the S Drive. Real Recruits Consulting Limited conduct strict right to work checks to ensure all candidates are compliant and eligible to work. This includes ensuring onsite identity documents match the candidate, video calling, onsite worker check-ins. All employees must evidence that they matched the original. Our CRM system operates a Compliance Screening module, which prevents workers with non- compliant records being booked onto an assignment. Our Central Services Team run monthly checks to ascertain duplicate bank accounts and proof of address checks to flag up any ‘patterns’ which may indicate Gangmaster activity. Where potential activity is highlighted, the Senior Management Team must be notified and provided the report. The SMT will instruct the People & Culture Team to carry out an investigation, including worker interviews and confidential surveys. Where necessary an interpreter must be arranged to support. In the event Gangmaster activity is identified we will collaborate with the Gangmasters and Labour Abuse Authority (GLAA) to collectively find a solution and share our knowledge. Branches have access to support systems, such as our dedicated Group Compliance Manager who conducts regular and thorough audits and our People & Culture team who run regular courses on the Stronger Together principles. All employees are issued an Employee Handbook which outlines company procedures and processes in tackling Modern Slavery; this is revised and reissued annually.

Training

Employees are taken through training to ensure they are aware of Modern Slavery and Hidden Labour Exploitation, their responsibilities within their role and steps to take to prevent the practices. The need for thorough recruitment practices is highlighted throughout training sessions, including compliance training, as many of these are ways in which to protect their candidates. Employees are also made aware of steps to take should they have any suspicions, which includes an escalation process to People & Culture and/or Senior Management and, where the temporary worker has been working for one of the Group’s clients, discussions with the HR Team or relevant contact on that site. Contact numbers for relevant support mechanisms (e.g. Modern Slavery Helpline, GLAA and the Police) are available within the training materials, as well as on posters in our branches which are visible to candidates and clients who may visit that site, as well as acting as an ongoing reminder and engagement tool for employees. Real Recruits Consulting Limited run compliance training for employees on a regular basis to ensure awareness and inspection in day to day practice. Regular sessions allow for our trainers to pass on new legislation and internal policy changes

Policy Commitments

1. Designate the People & Culture team to train consultants / managers on “Tackling Hidden Labour Exploitation”
and to have responsibility along with Compliance for developing and operating company procedures relevant to
this issue.
2. Accept that job finding fees are a business cost, (paid by clients) and will not allow these to be paid by job
applicants. The Company will not use any individual or organisation to source and supply workers without
confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third party labour
exploitation and signs to look for.
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and
competent employees.
5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing
Authority and police.
6. Provide information on tackling “Hidden Labour Exploitation” to our workforce and others through training,
processes and visible posters in the workplace displaying helplines.
7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and
investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be
occurring within their communities. Provide posters will helpline numbers.
9. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures
consistent with the above.

Definitions

Forced Labour is all work or service that is exacted from any person under the menace of any penalty and for which
the said person has not offered himself voluntarily.
• Human Trafficking is the recruitment and transportation of persons by threat, force, coercion or other abuse of power
or vulnerability to achieve the consent of a person having control over another person for the purpose of exploitation.
• Hidden Labour Exploitation is action up to and including modern slavery which involves the exploitation of workers
and job applicants by internal or external individuals without the sanction or explicit knowledge of the employer or
labour provider
• Debt-bonded Labour is where a person’s labour is demanded as a means of repayment for a loan or service