Background and Purpose
The purpose of this statement is to specify details of Affinity Workforce’s approach to fulfilling its commitment to support the elimination of Modern Slavery and fully meet its obligations under the Modern Slavery Act 2015 (the “Act”).
This statement covers the scope of our policies and procedures in relation to the Act; our commitment to eliminating Modern Slavery in all its forms; the risks that exist in our business and supply chain; and a review of the activities we have taken in the last 12 months, and plan to take in the next 12 months.
This statement applies to all businesses within the Affinity Workforce group of companies (the “Group”). The statement also applies to third party suppliers with access to Affinity Workforce or client property, systems or data, and any other parties working for or on behalf of Affinity Workforce.
Business Structure and Services
Affinity Workforce consists of a number of limited company subsidiaries operating in specific markets. Our brands provide recruitment, consultancy and HR services into the Education, Healthcare and Social Care sectors throughout the United Kingdom. We have an employee base of over 400 permanent employees, and we engage with and supply the services of contractors and agency workers across several professional disciplines.
The staff we supply to our customers operate in public services disciplines and the majority of our trade is with local authorities and health authorities, as well as a number of large corporate customers.
Our supplier base is made up of a mix of SMEs and large enterprises providing professional services, facilities and asset management services, IT software and infrastructure. Far and away our largest category of spend is with support suppliers engaged to provide the same or similar services to those provided by the Group itself under a formal supply chain management agreement.
As a recruitment and HR services group, people are at the heart of everything we do. Our commitment to preventing acts of modern slavery is embedded in our core business values, our people processes and our supply chain practices. This helps ensure that everyone who works for or on behalf of Affinity Workforce, in any capacity, and anywhere, benefits from a working environment in which their fundamental rights and freedoms are respected.
Our commitment to Modern Slavery is underpinned by a detailed framework of policies and procedures in place across the Group that promote ethical working practices and standards. These policies go beyond fundamental freedoms to ensure that all workers are engaged in safe working environments, that their well-being is considered in all aspects of their engagement, that they are treated equally and fairly and that they are always treated with dignity and respect. Together, our policies set out how we do business, how we engage with clients and manage our relationships with end customers, and how we manage suppliers and third parties.
We acknowledge and commit to the requirements of the Act and, within our remit, we ask third parties who represent us and suppliers who provide goods and/or services to us, to confirm their commitment alongside our commitment to the:
- UN Declaration of Human Rights;
- UN Guiding Principles on Business and Human Rights, and
- Core Conventions of the International Labour Organisation.
Given the nature of our business, we have regular contact with all workers who are engaged by us directly as well as all workers who are engaged through our supply chains, meaning we are quickly able to identify and flag any risks of workers having their rights or personal freedoms restricted and we are able to audit payments made to all workers. Our specialist sectors are also low risk on the basis that the workers we engage and supply are vetted to a high level (under safeguarding rules) and mostly working in roles that (a) require registration with a professional body and/or (b) have a high rate of membership with regards recognised trade unions.
We consider third parties who represent us and suppliers who provide goods and/or services as an extension of our business. That is why we work collaboratively with them to ensure they act in a way that is consistent with our values, our commitments and our policies.
We see our supply chain as a principal risk within our business and our approach to supply chain engagement is overseen by the Group Commercial Director.
Given the robust UK legislative framework the risk of infringement for our supplier employees working in UK offices is low. Nevertheless, we recognise our responsibility to identify and address potential infringements linked to the goods and/or services we procure. Therefore, we have put in place procedures to work to ensure that our suppliers adhere to the same standards as we apply to ourselves.
We hold a limited number of offshore contracts and we only work with businesses where we are allowed direct, regular contact and interaction with the workers engaged remotely on our behalf/providing products or services and where the supplier can provide evidence of its commitment to our policies and values, regardless of jurisdiction.
Steps Taken in 2017
2017 was the year that Affinity Workforce was formed as an independent group of specialist recruitment and HR services businesses, following the divestment of the Group from Capita plc on 1st June. Prior to this date, and during the transitional separation period, we remained subject to the broader Capita group policies, governance controls and reporting.
Nonetheless, we have taken significant steps in the last year to address the risk of Modern Slavery, both under Capita ownership and as an independent Group. These steps included:
- updating our Supplier Contract Terms and Conditions to reinforce and make clearer our expectations of our suppliers to help prevent any occurrence of Modern Slavery and Human Trafficking. This is an ongoing programme and changes are being included on all new contracts and at renewal;
- developing a new and more comprehensive due diligence evaluation process that is then supported by more robust visibility of how suppliers engage workers on our behalf, coupled with audit rights and procedures;
- updating our Group ethical working practices and policies following the divestment to ensure that they are more relevant, and more focused, to managing risks and compliance for a business of our nature, operating in our core markets.
Priorities for 2018
Our approach to promoting awareness of Modern Slavery and our compliance with the Act will continue to be on the Board’s agenda, for our progress to be reviewed on a regular basis. More specifically:
- we will continue to roll out the declaration on Modern Slavery held in our commercial contracts for our existing suppliers when renewing contracts;
- we will review our escalation and early-warning processes to ensure we can work effectively with suppliers to address issues that may arise from our due diligence and performance reviews including any required remediation;
- we will introduce a reference and peer review process for any offshore suppliers we engage;
- we will introduce a central referral process so that any stakeholder (employee, worker, customer, supplier or public body) can notify the board of any risks, issues or suggestions in a secure and anonymous manner; and
- we will continue to develop our supplier sign-up processes, evaluation and audit tools to improve our ability to identify risks and/or opportunities to introduce good practice.
Whilst we consider the markets and sectors we operate in as having a low risk of exposure to acts of Modern Slavery, we are aware of the devastating consequences these acts continue to have on the lives of individuals throughout the modern world, including here in the UK.
We understand that it is only through greater diligence and positive action that such acts can be eliminated and we remain committed to raising awareness among our businesses, our staff and our external stakeholders; ensuring that we consider the impact on personal rights and freedoms in everything that we do as a Group.
On behalf of the board
CEO, Affinity Workforce