1: Opening statement from senior management
Empresaria Group plc is committed to preventing all forms of slavery, servitude, forced labour, debt bondage and human trafficking from occurring within its business and supply chain, and expects the same high standards from its suppliers.
2: Structure of the organisation and supply chains
Empresaria Group plc is a global recruitment and staffing business. We are part of the Empresaria group of companies (the ‘Empresaria Group’).
Our brands operate in 21 different countries in Europe, the Americas and Asia Pacific. A full list of companies within the Empresaria Group and their locations can be found in our Annual Reports, which can be downloaded here.
In 2019, Empresaria Group plc had a global annual turnover of £358m. One of our group companies also exceeded the tthreshold for modern slavery reporting in is own right, namely headwaylogistic GmbH (Germany).
As our business is staffing and recruitment, our supply chains are very limited, being largely restricted to those supplying clerical goods and services to our offices.
3: Policies on modern slavery
As part of our commitment to combating modern slavery, we have implemented the following policies across the entire Empresaria Group:
Modern Slavery Policy
Whistleblowing Policy
We expect our suppliers to adhere to our policies where applicable and have a zero-tolerance approach to non-compliance.
4: Due diligence processes
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have continued the following due diligence procedures:
identifying and assessing potential risk areas in our group companies;
identifying and assessing potential risk areas in our supply chains, where appropriate;
introducing preventative measures where high risks are identified;
mitigating the risk of slavery and human trafficking occurring in our supply chains;
protecting whistle blowers.
5: Risk assessment
Empresaria Group plc regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its business and supply chains.
The nature of our business means that we supply or introduce individuals to work for our clients. We undertake compliance checks on prospective workers to confirm their identity, proof of address, right to work and other appropriate checks. We also require our clients to provide a safe working environment for our workers.
Our consultants maintain contact with workers supplied to our clients throughout the length of their assignments to ensure their safety and allow them to raise any concerns.
Many of our businesses provide recruitment services in relation to highly qualified and skilled individuals. They are predominantly engaged as professionals and/or in clerical/office-based environments in sectors at low risk of modern slavery, such as IT, professional services and aviation. In addition, the majority of the locations in which we operate are considered to be at very low risk of modern slavery. We therefore consider that most of our businesses do not operate in high risk sectors or locations.
However, where our businesses do supply or introduce lower skilled individuals into higher risk sectors (such as manufacturing or hospitality) and where we operate in locations considered to be higher risk, we review our processes regularly and introduce preventative measures if appropriate.
To date, we have not identified any instances of modern slavery in our business or supply chains.
6: Measuring effectiveness
Empresaria Group plc has a compliance team trained to assess our businesses and identify risks associated with failure to comply with legal and regulatory requirements, including risks associated with modern slavery both in the UK and internationally.
We have reviewed the effectiveness of the measures taken to date and are committed to continuous improvement in identifying and evaluating risks and developing measures to help prevent modern slavery and human trafficking in our business or supply chains.
7: Training
Our compliance team is trained to assist our businesses in ensuring that modern slavery and human trafficking do not occur in our businesses or supply chains. All staff are expected to understand and follow the Modern Slavery Policy.
This helps to ensure that staff at all levels within each business are sufficiently aware of the likely indicators of modern slavery to help them identify possible instances and ensure that they know when and how to raise any concerns.
8: Further actions and sign-off
In 2019 we carried out the following steps:
we continued to incorporate specific modern slavery provisions in our agreements with hirer clients as well as in our revised standard client terms;
all group companies were asked to provide a detailed analysis of their supply chain and assessment of risks to provide an overview of risk;
we used the information collated to assess training needs and identify areas where further preventative measures could be implemented.
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps:
continue to incorporate specific modern slavery provisions in our agreements with new hirer clients;
refine the scope of due diligence assessments for group companies operating in higher risk sectors and/or locations;
provide further training to key employees in our operating companies, where appropriate;
introduce modern slavery checklists for companies supplying staff in high risk sectors or countries.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Empresaria Group plc's slavery and human trafficking statement for the financial year ended 31 December 2019.
This statement was approved by the Board of Directors on 26 May 2020.
Rhona Driggs
Chief Executive Officer
26 May 2020