Although my company does not fall under the requirements of the Modern Slavery Act 2015 (Turnover less than £36 Million) I am committed to ensuring acts of modern-day slavery and human trafficking will never be an issue within my company and its supply chain, including sub-contractors, and partners.

I will ensure that there is full transparency within my Company and our Suppliers of goods and services to the organisation with a commitment to:

• Legal compliance, ethical standards and fundamental human rights as set out by the principles of the ILO/UN Guiding Principles
• Raising awareness of modern slavery issues including how to spot the signs in the business and supply chain
• Provide whistleblowing and/or other mechanisms for reporting issues
• Nominated a person at the most senior management level within the business that has responsibility for the prevention modern slavery within the business
• Address and directly prohibit practices that are known to contribute to the risk of modern slavery
• Due diligence requirements for the business and supply chain and the steps it will take should modern slavery practices be identified within either
• Identification of and management of any high-risk materials/labour sourcing

Furthermore:

As part of my Company’s due diligence processes into slavery and human trafficking the supplier approval process will incorporate a review of the controls undertaken by the supplier whenever the Supplier falls under the requirements of the Modern Slavery Act.

Imported goods from sources from outside the UK and EU are potentially more at risk for Slavery/Human trafficking issues. The level of management control required for these sources will be continually monitored. 

I will not permit my company to support or deal with any business knowingly involved in slavery or human trafficking. The nominated person shall take responsibility for implementing this policy statement and its commitments and shall provide when adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation or within its supply chains. 

A copy of this Policy Statement and accompanying Procedure will be made available and communicated to and understood by all of our Employees and where necessary our External Providers with a copy of the Modern Slavery Act 2015 held within the Legislation Register and available to all employees upon request. 

Formal procedures concerning slavery and human trafficking will be established, when required including disciplinary procedures where the requirements of the Act have been identified as being breached.

This Procedure and Associated Policy Statements form Think Hire’s Modern Slavery Statement for the financial year and are reviewed annually as part of the Annual Management Review process.

Neil Richardson

Managing Director
ThinkHire