Modern Slavery Policy

What is this policy for?

This policy sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and supply chains.

Our structure and supply chains

This policy covers the activities of Octave Recruitment Ltd

Recruitment agency providing temporary and permanent staffing in various sectors including Admin, Housing, Customer Service, Health and Social Care, Trades and Labour.

Countries of operation and supply

We operate in the following countries:

The following is the process by which we assess whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

Policies: Data Privacy Policy, Whistleblowing policy, Employer code of conduct, Employee code of conduct, Supplier terms of engagement.
Risk assessments/ Investigations/due diligence: Evaluating the modern slavery risks and policies of each new supplier, reviewing on a regular basis, using approved and audited suppliers. Employing rigorous right to work and identity checks for each person.
Training: Reviewing that each new supplier is offering training on the risks of modern slavery and human trafficking. Ensuring all staff complete modern slavery training.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

Whistleblowing policy – We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or our supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our contact form anonymously.
Employee code of conduct – Our code makes clear to employees the actions and behaviour expected of them when representing us. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Supplier/Procurement] code of conduct – We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship. All supplier contracts go through due diligence and checks before approval.

Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include:

Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.
Evaluating the modern slavery and human trafficking risks of each new supplier.
Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
Conducting supplier audits or assessments.
Creating an annual risk profile for each supplier.
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

Requiring all staff to have completed training on modern slavery by 31/03/2024.
Developing a system for supply chain verification [in place since 01/06/2021, whereby we evaluate potential suppliers before they enter the supply chain; and
reviewing our existing supply chains completed on 01/12/2023 whereby we evaluate all existing suppliers.

Training

We require all staff to complete training on modern slavery.

Our modern slavery training covers:

Our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline.
How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
How to identify the signs of slavery and human trafficking.
What initial steps should be taken if slavery or human trafficking is suspected.
How to escalate potential slavery or human trafficking issues to the relevant parties to us.
What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative.
What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
What steps we should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.