MODERN SLAVERY
POLICY

Netbox Recruitment Ltd - Modern Slavery Policy

1. Netbox Recruitment Ltd is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.

2. Netbox Recruitment Ltd is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

3. Netbox Recruitment Ltd provides appropriate training and awareness information for all of its staff.

In particular:

• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

4. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to Sarah Gilbertson - Director

5. Reports surrounding these issues are taken extremely seriously by the senior leadership team who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

• Working with the appropriate organisations to improve standards,
• Removing that organisation from our preferred supplier list
• Passing details to appropriate law enforcement bodies.

6. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:

• The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements,
• The level of modern slavery training and awareness amongst our staff.

7. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

This policy was adopted on 01.12.2019 after being agreed by our Directors. It is reviewed annually.

Netbox Recruitment Ltd - Modern Slavery Statement

This statement is made as part of Netbox Recruitment's commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Netbox Recruitment Ltd operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

Sarah Gilbertson-Director 01732 671 121 Option 2

1. Our Business

Netbox Recruitment Ltd is a limited company operating in the recruitment sector. We provide introduction services and supply temporary workers in the generalist commercial market.
Netbox Recruitment Ltd is an independent business.

1.1 Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. We do not supply work-seekers to hiring companies through any intermediaries.

1.2 Other relationships

As part of our business, we also work with the following organisations:

The Recruitment and Employment Confederation (www.rec.uk.com) and the Institute of Recruitment Professionals (www.rec-irp.uk.com)

2. Our Policies

Netbox Recruitment Ltd has a modern slavery policy available at www.netboxrecruitment.com

In addition, Netbox Recruitment Ltd has the following policies which incorporate ethical standards for our staff.

2.1 Whistleblowing policy

The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's 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 [use our confidential helpline/complete our confidential disclosure form].

2.2 Employee code of conduct

The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

2.3 Policy development and review

Netbox Recruitment's policies are established by our directors, based on advice from HR professionals, industry best practice and legal advice. We review our policies on a regular basis, or as needed to adapt to changes.

3. Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

• We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.

Additionally, we have taken the following steps to minimise the possibility of any problems:

• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.

Our staff are encouraged to bring any concerns they have to the attention of management.

4. Our Performance

As part of monitoring the performance of Netbox Recruitment Ltd, we track the following general key performance indicators:

• The level of training amongst staff
• Timeframes in which we investigate related complaints

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our directors

• The effectiveness of enforcement against suppliers who breach policies
• The level of modern slavery training and awareness amongst our staff

We benchmark our indicators against industry best-practice, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

5. Our Training

All of our staff receive training and support that is appropriate to their role. In particular:

• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this, our staff are encouraged to discuss any concerns that they have.

Training is refreshed regularly.