Pursuant to Section 54 (1) of the Modern Slavery Act 2015, this statement constitutes our slavery and human trafficking statement and outlines NES’ approach to tackling modern slavery. This statement is made by NES Global Talent Limited and each of its UK subsidiaries (*listed below), that are required to make such a statement in accordance with the Act.
Our Approach & Commitment
Personal integrity and responsibility are the foundation of our business; we differentiate our solutions on the basis of compliance, integrity and responsibility, and in accordance with local and international laws. Within this context, NES will not accept any practices involving slavery, servitude, forced or compulsory labour, or human trafficking. We are committed to these principles and to taking all reasonable steps to ensure slavery and human trafficking are not taking place within our business, that of our partners or the ensuing supply chain.
NES’ business conduct is defined by our core business values and a series of corporate policies which collectively outline NES’s ‘Expected Business Conduct’; a framework of legal, ethical and industry standards targeted at NES stakeholders at all levels.
Our Business Ethics Policy sets out the high ethical standards expected across our global operations and works to ensure that these standards are communicated and understood by NES employees and companies with which NES do business with. Our policies support NES’ commitment to ensure basic human rights principles are afforded to individuals and outlines the principles that guide our business practices. All NES employees are required to comply with business policy.
Expected Business Conduct clearly states that NES will not tolerate practices that do not meet our ethical standards.
A majority of our supply chain incorporates business partners and professional consultancy services, namely financial or legal specialists, or organisations that partner with NES in the mobilisation of personnel. A further proportion of our supply chain is linked to commodities, such as utilities, workplace equipment and welfare provisions.
Our supplier evaluation process incorporates a detailed Code of Conduct for Business Partners & Suppliers, obligating external providers to declare their commitment to ethical standards, including anti-slavery and the avoidance of any human trafficking or forced labour practices within their own business and throughout their supply chain.
Our Management Controls
Our recruitment processes underpin expectations from employees, suppliers and customers, and act to ensure transparency in our recruitment operations for an assurance that individuals are not being placed into any situation that may be construed as Modern Slavery.
Controls include, but are not limited to:
- Placements being subject to compliance checks deriving from legal, industry and contractual obligations;
- Recruitment protocol and expected business conduct obligations being communicated throughout global operations;
- Terms of Business with clients and Contract for Services with contractors are agreed in all instances; and
- Supplier evaluations incorporate a formal ‘Code of Conduct’ and declarations of compliance as part of NES’ approval process.
Continual Improvement is important for NES; we will continue to assess risk associated with modern slavery across the business and within our supply chain, whether such risks are directly or indirectly linked to our business activity, or relating to the geographical areas in which we operate. We shall continue to focus on understanding the indicators of modern slavery, exposure areas or vulnerable groups associated with our business, and work to mitigate any perceived risks through comprehensive control measures
Performance Monitoring shall be undertaken in line with our risk management measures to verify compliance and effectiveness of the controls in place. Policy and associated documents are subject to regular audit and review.
Training & Awareness for employees is delivered through NES’ Expected Business Conduct framework. Training is mandatory for employees; business ethics being a key module for review, acknowledgement and acceptance. 2018 saw increased focus on Business Ethics resulting in a suite of Modules being tailored for new members of the NES team, and a refresher module aimed at existing employees.
Awareness continues to be a focus for NES and we have allocated a central incident reporting area for the purpose of reporting any concerns or issues relating to expected business conduct, and more specifically any Modern Slavery or Human Trafficking concerns or instances.
This Statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the financial year ending 31st October 2018. Content has been approved on behalf of the Board of Directors.
Chief Financial Officer
11th April 2019.
*NES Global Talent Limited and its UK subsidiaries, principally, NES Group Limited, NES UK Limited, NES Global Limited, NES Managed Services Limited, NES Recruitment Limited, NES Advantage Solutions Limited.