Modern Slavery Statement

Modern Slavery Statement

1: Opening statement from senior management

This statement is made on behalf of Empresaria Group plc and each of its subsidiaries (Group Company) (which together are referred to as the Empresaria Group, ‘we’, ‘us’ or ‘our’ throughout this statement).


This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Empresaria Group’s slavery and human trafficking statement for the financial year ended 31 December 2023.


The Empresaria Group 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.


Empresaria Group plc is a member of REC (the Recruitment and Employment Confederation) and APSCo (the Association of Professional Staffing Companies).


2: Structure of the organisation and supply chains


The Empresaria Group is a global recruitment and staffing business. In 2023, Empresaria Group plc had a global annual turnover of £250m.


Our brands operate in 18 different countries in Europe, the Americas and Asia Pacific. A full list of Group Companies and their locations can be found in our Annual Reports, which can be downloaded from our website at: https://www.empresaria.com/financial-information/company-reports.


As a provider of services rather than goods, our supply chains are limited, being largely restricted to suppliers providing office supplies and services such as IT and payroll to our Group Companies.


3: Policies on modern slavery


As part of our commitment to combating modern slavery, all staff across the Empresaria Group are required to comply with our policies, which are updated from time to time, including our:


  • Modern Slavery Policy;
  • Whistleblowing Policy;
  • Code of Conduct.


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


Our businesses are constantly evolving. The Empresaria Group 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.


Most 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 and professional services. Most of the locations in which we operate are at very low risk of modern slavery, for example the UK, US, Germany, Australia and New Zealand. We therefore consider that most of our businesses do not operate in high-risk sectors or locations.


However, where our Group Companies do supply or introduce lower skilled individuals within higher risk sectors (such as manufacturing), or where we operate in higher risk locations (such as the Philippines, Malaysia, Thailand or India), we review our processes regularly and introduce preventative measures if appropriate.


Most of our supply chains are low risk in terms of modern slavery. Where we have identified a higher risk of modern slavery in certain types of suppliers, such as umbrella companies, we have strict compliance procedures in place and use only accredited or recommended suppliers.


Senior management across our Group Companies have received training on high-risk locations and high-risk sectors, and how to report potential modern slavery incidents and are responsible for ensuring that this information flows down to all employees within their business units.


To date, no instances of modern slavery have been identified anywhere in the Empresaria Group or in our supply chains and there have been no reported breaches of the Modern Slavery Act 2015.


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.


In 2023, we also updated and delivered modern slavery training to senior employees across our Group Companies, who have been tasked with flowing the information down to all employees within their business units.

 

All staff are expected to read and follow the Modern Slavery Policy and to familiarise themselves with our Modern Slavery Policy and the training materials provided. All employees are able to access the Modern Slavery Policy and our modern slavery training materials at any time.


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 2023 we carried out the following steps:


  • we used information collated from detailed analysis of each business to assess training needs and identify areas where further preventative measures could be implemented;
  • each operating Group Company has a designated senior employee to take responsibility for modern slavery matters within each business;
  • we continued to incorporate specific modern slavery provisions in our agreements with hirer clients where possible, as well as in our standard terms of business;
  • we maintained a central policy hub where all staff across the Empresaria Group can easily access all our policies, including the Empresaria Group’s Modern Slavery Policy and modern slavery training materials, allowing us to update them and notify staff of changes easily;
  • we updated and delivered training, tailored for our businesses to senior management within each of our Group Companies.


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;
  • assess and where appropriate update training for key employees in our Group Companies;
  • continue to work together to improve awareness of the issue of modern slavery and ensure all staff are informed of their responsibilities;
  • review the additional safeguards and/or compliance checks we have put in place for our businesses operating in higher risk locations or sectors.


This statement was approved by the Board of Directors on 21 May 2024 and signed on its behalf by Rhona Driggs, CEO, on 27 May 2024.