Hollborn Recruitment Ltd

Address: 38 Romford Road, Stratford, London, E15 4BZ
Phone: +44 7349 560154
Email: info@hollbornrecruitment.co.uk
Website: www.hollbornrecruitment.co.uk

1. Introduction

Hollborn Recruitment Ltd is committed to preventing modern slavery, forced labour, human trafficking, and exploitation in all areas of its business operations and supply chains.

We recognise our responsibility to operate ethically and with integrity in all business relationships and to implement effective systems and controls to ensure that modern slavery does not occur within our organisation or through our partners.

This policy is developed in accordance with the Modern Slavery Act 2015 and relevant UK government guidance and reflects our commitment to protecting human rights and promoting fair and lawful employment practices.

2. Policy Statement

Hollborn Recruitment Ltd operates a zero-tolerance approach to modern slavery and human trafficking.

We are committed to conducting business in a transparent, responsible, and ethical manner and expect the same standards from all:

• employees

• contractors

• suppliers

• clients

• business partners

We will not knowingly support or tolerate:

• slavery

• servitude

• forced or compulsory labour

• bonded labour

• child labour

• human trafficking

3. Legal Framework

This policy is based on the following UK legislation and guidance:

• Modern Slavery Act 2015

• Immigration, Asylum and Nationality Act 2006

• Employment Rights Act 1996

• National Minimum Wage Act 1998

• Home Office Modern Slavery Guidance

• Gangmasters and Labour Abuse Authority (GLAA) standards

Failure to comply with these laws may result in legal penalties, reputational damage, or termination of business relationships.

4. Scope of This Policy

This policy applies to all individuals working for or on behalf of Hollborn Recruitment Ltd, including:

• employees

• agency workers

• candidates

• contractors

• suppliers

• clients

• business partners

The policy covers all business activities, recruitment practices, and supply chain relationships.

5. Responsibilities

Management Responsibilities

Senior management is responsible for:

• implementing this policy

• monitoring compliance

• promoting ethical working practices across the organisation

• addressing risks relating to modern slavery

Staff Responsibilities

All staff must:

• understand and comply with this policy

• remain alert to potential risks of exploitation

• report concerns immediately

• treat all individuals fairly and respectfully

• participate in relevant training where required

Failure to comply with this policy may result in disciplinary action.

6. Risk Assessment

Hollborn Recruitment Ltd regularly assesses potential risks of modern slavery within its operations and supply chains.

This includes reviewing:

• recruitment methods

• employment practices

• client relationships

• supplier arrangements

Particular attention is given to areas that may present higher risks, including:

• temporary or low-skilled work

• overseas recruitment

• vulnerable workers

Where risks are identified, appropriate action is taken to reduce or eliminate them.

7. Recruitment and Employment Practices

We maintain fair, transparent, and lawful recruitment practices.

All workers are recruited voluntarily and are free to leave employment in accordance with their contracts and applicable law.

We ensure that:

• workers are not charged recruitment fees

• employment terms are clearly explained

• wages are paid directly to workers

• right-to-work checks are completed

• working hours comply with legal requirements

• workers retain control of their personal identification documents

Any practice that restricts freedom, movement, or choice is strictly prohibited.

8. Due Diligence and Supply Chain Management

Hollborn Recruitment Ltd undertakes due diligence on suppliers, clients, and business partners to ensure compliance with ethical and legal standards.

This may include reviewing:

• policies and procedures

• contractual agreements

• compliance history

Suppliers and partners are expected to:

• comply with the Modern Slavery Act 2015

• maintain lawful and ethical employment practices

• cooperate with compliance checks or investigations where necessary

Contracts may be terminated where serious breaches are identified.

9. Training and Awareness

Relevant staff receive training to help identify and prevent modern slavery risks.

Training includes:

• recognising indicators of exploitation

• reporting procedures

• legal obligations under modern slavery legislation

Training is provided during staff induction and refreshed periodically.

10. Identifying Warning Signs

Staff are trained to recognise possible indicators of modern slavery or exploitation, including:

• workers appearing fearful, withdrawn, or controlled

• lack of personal identification documents

• restricted freedom of movement

• unusual or unexplained payment arrangements

• signs of debt bondage

• poor living or working conditions

• inability to communicate freely

Any concerns must be reported immediately.

11. Reporting and Whistleblowing

Hollborn Recruitment Ltd encourages all staff and workers to report concerns regarding modern slavery.

Reports can be made to:

• management

• HR representatives

• designated reporting channels

Reports will be handled confidentially and without retaliation.

All concerns will be taken seriously and investigated promptly.

12. Response and Remedial Action

Where modern slavery or exploitation is suspected or identified, Hollborn Recruitment Ltd will:

• take immediate action to protect affected individuals

• cooperate with relevant authorities

• terminate relationships with offending parties where appropriate

We may work with agencies such as:

• law enforcement

• the Home Office

• the Gangmasters and Labour Abuse Authority (GLAA)

• support organisations assisting victims of exploitation

13. Monitoring and Review

We regularly monitor our practices and supply chains to ensure compliance with this policy.

This includes:

• internal audits

• compliance reviews

• risk assessments

The policy and related procedures are reviewed periodically to ensure ongoing effectiveness.

14. Transparency Statement

Hollborn Recruitment Ltd supports transparency under Section 54 of the Modern Slavery Act 2015.

Where required, we publish a Modern Slavery Statement outlining the steps taken to prevent modern slavery and human trafficking within our operations and supply chains.

15. Data Protection

Any personal data obtained during investigations or reporting of modern slavery concerns is handled in accordance with:

• UK GDPR

• Data Protection Act 2018

• Hollborn Recruitment Ltd Data Protection Policy

All information is treated confidentially and used only for lawful purposes.