Proman commits to developing and adopting a proactive approach to tackling hidden labour exploitation. Hidden labour exploitation is exploitation of job applicants or workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as the forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims if they perceive of themselves as such, reluctant to come forward.
Proman currently operates in the North West of England, Yorkshire, the Midlands, London and Bristol.
The Compliance Director and members of the Compliance Team are responsible for the deployment of this policy and accompanying procedures to Branch Managers, Account Managers, Payroll staff and our Clients.
1. The Compliance Director to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
2. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.
6. Provide information on tackling “Hidden Labour Exploitation” to our employees and our Agency Worker workforce through a variety of formats such as workplace posters, worker leaflets, inductions, and assignment information.
7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities (detail how).
9. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.
Legal & Compliance Director
Tackling Modern Slavery Statement
This statement is made as part of Proman’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Proman 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.
This statement is published in accordance with section 54 of the Act and relates to the financial year Jan 2019 to Dec 2019. It was approved by the board of directors on 26/01/2019.
Legal & Compliance Director
"Proman" is the trading name of a group of limited companies operating in the recruitment sector. We provide introduction services and supply temporary workers in the Supply Chain, Engineering and Construction Sectors.
The group of companies trading as "Proman" includes HEADS Recruitment Ltd (Company Number 3443013), HEADS Engineering Ltd (Company Number 4163986), and PROMAN Recruitment Ltd (Company Number 9907561).
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. Some of these work-seekers operate through their own limited companies. Some of our work-seekers are supplied via other businesses, which facilitate providing them to the eventual hiring company.
The hiring companies and the workers that we work with and supply are located within the UK.
As part of our business, we also work with the following organisations:
Proman has a modern slavery policy available here.
In addition, Proman has the following policies which incorporate ethical standards for our staff [and our suppliers].
- Anti-Bribery Policy
- Ethical Trading Policy
- Annual Policy development and review
Proman’s policies are established by our directors, based on advice from HR professionals, industry best practice and legal advice, and in consultation with the Recruitment and Employment Confederation. We review our policies annually or as needed to adapt to changes.
OUR PROCESSES FOR MANAGING RISK
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
- When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
- We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.
- 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 identified the following potential risks in our supply chain:
- Sector risks, because there may be substantially different working practices between different sectors,
- Business partnership risks, acknowledging that different relationships your business has may have different risks associated with them. This can involve a variety of factors including knowledge and familiarity with the other business’s working practices, the length of the relationship, and any due diligence (audits etc.) you have conducted.
Additionally, we have taken the following steps to minimise the possibility of any problems:
- We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
- We require the businesses we work with to address modern slavery concerns in their policies.
- 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 an area where we have identified the potential for risk.
- We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
- We work with “Stronger Together”, “Gangmasters and Labour Abuse Authority (GLAA)” and the “Recruitment and Employment Confederation” in order to combat the risk of modern slavery and human trafficking.
Our staff are encouraged to bring any concerns they have to the attention of management.
As part of monitoring the performance of Proman and we track the following general key performance indicators:
- All operations staff completes annual refresher training and assessment of recruitment technical knowledge including our ‘tackling modern slavery’ process and procedures.
- All complaints are acknowledged within 48 hours and investigated within 7 days.
- Reports of possible incidents of Modern Slavery.
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of directors:
- the level of modern slavery training and awareness amongst our staff
We carefully consider our indicators, in order to ensure that we do not put undue pressure on our employees that might increase the potential for risk.
All of our staff receives training and support that is appropriate to their role. In particular:
- Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
- Our recruiters undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
- 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 annually.