BBS Recruitment Agency – Modern Slavery Statement 2024
This statement is issued in accordance with the Modern Slavery Act 2015. It sets out the steps we have taken in the year to 29 February 2024 to address and prevent modern slavery and human trafficking within our operations and supply chains.
BBS Recruitment Modern Slavery Act Statement
We are committed to tackling the risk of modern slavery within our organisation and wider supply chains. We actively promote inclusion and diversity, and any unfair or discriminatory treatment of individuals is wholly inconsistent with our values as a recruitment agency.
Modern Slavery and Human Trafficking Policy
- Policy Statement
1.1. Modern slavery is a crime and a violation of fundamental human rights. It includes slavery, servitude, forced and compulsory labour, and human trafficking. These forms of exploitation involve depriving individuals of their liberty for personal or commercial gain. We operate a zero-tolerance approach to all forms of modern slavery and are committed to acting ethically and with integrity in all business dealings. We maintain effective systems and controls to ensure modern slavery does not occur in our business or supply chains.
1.2. We are committed to transparency in our business and supply chains in line with our obligations under the Modern Slavery Act 2015. We expect the same high standards from all contractors, suppliers, and business partners. Our contracting processes include explicit prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude—whether adults or children. We expect our suppliers to apply the same standards throughout their own supply chains.
1.3. This policy applies to all individuals working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, secondees, volunteers, interns, contractors, consultants, third-party representatives, and business partners.
1.4. This policy does not form part of any employee’s contract of employment and may be amended at any time.
- Responsibility for the Policy
2.1. The Regional Manager has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all individuals under our control adhere to it.
2.2. The Regional Manager also has day-to-day responsibility for implementing this policy, monitoring its effectiveness, responding to queries, and ensuring internal systems and controls remain effective in preventing modern slavery.
2.3. Line managers are responsible for ensuring their teams understand and comply with this policy and receive adequate training on modern slavery risks and responsibilities.
2.4. We welcome feedback on how this policy can be improved. Comments and suggestions should be directed to the person responsible for the policy.
- Compliance With the Policy
3.1. You must read, understand, and comply with this policy.
3.2. Preventing, detecting, and reporting modern slavery within our business or supply chains is everyone’s responsibility.
3.3. You must notify your manager if you believe or suspect that a breach of this policy has occurred or may occur.
3.4. You are encouraged to raise concerns regarding any suspicion of modern slavery at the earliest opportunity.
3.5. Suspected breaches must be reported to your manager or through our Whistleblowing Policy.
3.6. If unsure whether certain behaviour or conditions constitute modern slavery, raise the issue with your manager or the Head of Procurement.
3.7. We encourage openness and will support anyone who raises genuine concerns in good faith, even if mistaken. No one will suffer detrimental treatment for reporting their concerns. Any employee who feels they have been treated unfairly after raising a concern should inform the Head of Procurement and, if unresolved, use the Grievance Procedure.
- Communication and Awareness
4.1. Training on this policy forms part of the induction process for all staff. Refresher training will be provided where necessary.
4.2. Our zero-tolerance approach must be communicated to all suppliers, contractors, and business partners at the start of our relationship and reinforced where appropriate.
- Breaches of the Policy
5.1. Any employee found to be in breach of this policy may face disciplinary action, up to and including dismissal for misconduct or gross misconduct.
5.2. We may terminate our relationship with any individual or organisation working on our behalf if they breach this policy.
BBS RECRUITMENT
Modern Slavery and Human Trafficking Statement & Policy 2026
Our Commitment to Ethical and Responsible Recruitment
BBS Recruitment is committed to conducting business ethically, responsibly and with integrity. We recognise our responsibility to help prevent modern slavery, human trafficking, forced labour and exploitation within our business operations, recruitment activities and supply chains.
This policy has been prepared with reference to the Modern Slavery Act 2015 and reflects our commitment to protecting human rights, promoting fair employment practices and maintaining professional recruitment standards.
As a recruitment agency supplying temporary and permanent staff across a range of sectors, including Clerical, Engineering Driving, Industrial, and Construction, we recognise the importance of ensuring that workers are treated fairly, respectfully and lawfully.
We operate a zero-tolerance approach to modern slavery and human trafficking and expect the same standards from our employees, clients, contractors, suppliers and business partners.
- Policy Statement
1.1. Modern slavery is a serious crime and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour and human trafficking, where individuals are exploited for personal, financial or commercial gain.
1.2. BBS Recruitment is committed to preventing all forms of modern slavery and exploitation within our business and supply chains. We will not knowingly engage with any individual, organisation or business involved in such practices.
1.3. We believe every individual has the right to work in a safe environment, receive fair treatment and be free from intimidation, coercion, discrimination and exploitation.
1.4. We expect all employees, agency workers, contractors, suppliers and business partners to uphold these principles and comply with applicable employment and human rights legislation.
1.5. This policy applies to everyone working for or representing BBS Recruitment, including directors, managers, employees, temporary workers, agency workers, consultants, contractors and third-party service providers.
1.6. This policy does not form part of any employment contract and may be reviewed or amended when necessary.
- Our Recruitment Responsibilities
2.1. As a recruitment agency, BBS Recruitment recognises that temporary and agency workers may be particularly vulnerable to exploitation, including unfair working conditions, unlawful deductions, intimidation and restrictions on personal freedom.
2.2. We are committed to promoting fair and transparent recruitment practices and taking reasonable steps to identify and address potential risks of modern slavery.
2.3. Our recruitment standards include:
- Verifying candidates’ identities and their legal right to work in the United Kingdom.
- Providing clear information about job opportunities, working arrangements and relevant employment conditions.
- Ensuring that workers are not charged unlawful recruitment or work-finding fees.
- Promoting fair treatment, lawful payment practices and appropriate working conditions.
- Taking reasonable steps to identify suspicious recruitment arrangements or signs of exploitation.
- Respecting workers’ freedom to leave employment in accordance with applicable contractual and legal requirements.
- Never retaining workers’ original passports or identity documents as a means of control.
- Encouraging workers to report concerns without fear of retaliation.
2.4. We will not tolerate threats, intimidation, harassment, forced labour, debt bondage or any form of coercion involving workers supplied or employed through BBS Recruitment.
- Responsibility for the Policy
3.1. The Company Directors have overall responsibility for ensuring that BBS Recruitment maintains appropriate policies and procedures to address the risks of modern slavery and human trafficking.
3.2. Management is responsible for implementing this policy, monitoring compliance and responding appropriately to any concerns raised.
3.3. Recruitment consultants and line managers are responsible for understanding this policy and applying its principles throughout the recruitment process.
3.4. All employees and representatives of BBS Recruitment have a responsibility to remain alert to potential signs of exploitation and report concerns promptly.
3.5. The Company Directors will review this policy periodically and make improvements where necessary to reflect changes in legislation, operational requirements and identified risks.
- Identifying and Preventing Modern Slavery
4.1. BBS Recruitment recognises that modern slavery can occur in many forms and may not always be immediately apparent.
4.2. Potential warning signs may include:
- Workers appearing frightened, intimidated or controlled by another individual.
- Individuals being unable to access their own identification documents.
- Workers reporting that their wages are being withheld or unlawfully deducted.
- Evidence of threats, coercion, debt bondage or restrictions on movement.
- Individuals being forced to work excessive hours against their will.
- Workers being prevented from communicating freely or raising concerns.
- Signs of unsafe, overcrowded or exploitative living or working arrangements.
- A third party exercising inappropriate control over a worker’s employment, wages or personal circumstances.
4.3. Where concerns arise, BBS Recruitment will take appropriate steps to assess the situation, protect individuals where possible and escalate matters to the relevant authorities when necessary.
4.4. We will not knowingly continue business relationships involving modern slavery or human trafficking.
- Working With Clients and Suppliers
5.1. BBS Recruitment expects its clients, suppliers, contractors and business partners to conduct their activities ethically and comply with applicable legislation.
5.2. We encourage organisations we work with to maintain appropriate employment practices, respect workers’ rights and take reasonable steps to prevent exploitation.
5.3. Where potential risks are identified, we may seek further information, request corrective action or review the business relationship.
5.4. We reserve the right to suspend or terminate relationships with organisations where serious concerns relating to modern slavery are substantiated and appropriate corrective action is not taken.
5.5. We expect our suppliers and business partners to apply comparable standards throughout their own operations and supply chains.
- Reporting Concerns and Whistleblowing
6.1. BBS Recruitment encourages employees, agency workers, contractors, candidates and other individuals to report any suspected modern slavery, exploitation or human trafficking.
6.2. Concerns should be reported promptly to a manager or Company Director.
6.3. Individuals may also raise concerns confidentially through the company’s established reporting procedures.
6.4. We are committed to treating genuine concerns seriously, handling reports sensitively and protecting individuals who raise concerns in good faith from victimisation or retaliation.
6.5. Where appropriate, BBS Recruitment will cooperate with relevant authorities and organisations investigating suspected exploitation.
6.6. Anyone who believes an individual is in immediate danger should contact the emergency services by calling 999.
6.7. Concerns about potential modern slavery may also be reported to the UK Modern Slavery & Exploitation Helpline on 08000 121 700.
- Training and Awareness
7.1. BBS Recruitment recognises the importance of ensuring that employees involved in recruitment understand the risks and warning signs associated with modern slavery.
7.2. We aim to promote awareness of this policy through appropriate staff communication, induction procedures and training relevant to individual responsibilities.
7.3. Recruitment consultants and managers are expected to understand their responsibilities for identifying and reporting potential exploitation.
7.4. Additional guidance or refresher training may be provided where appropriate.
- Equality, Diversity and Fair Treatment
8.1. BBS Recruitment is committed to promoting equality, diversity, inclusion and fair treatment throughout its recruitment activities.
8.2. We believe that every individual deserves to be treated with dignity and respect, regardless of background, nationality, race, gender, religion, disability, age or other protected characteristics.
8.3. Discrimination, harassment, exploitation and unfair treatment are inconsistent with our values and professional standards.
8.4. Recruitment decisions should be based on relevant qualifications, skills, experience and legitimate job requirements.
- Breaches of This Policy
9.1. Any employee found to have breached this policy may be subject to disciplinary action, which could include dismissal, depending on the seriousness of the breach and applicable procedures.
9.2. Where a contractor, supplier or business partner is found to have engaged in modern slavery or human trafficking, BBS Recruitment may suspend or terminate the relevant business relationship.
9.3. Suspected criminal activity may be reported to the appropriate authorities.
9.4. All reported concerns will be considered carefully, and appropriate action will be taken based on the circumstances.
- Monitoring and Continuous Improvement
10.1. BBS Recruitment is committed to reviewing its approach to preventing modern slavery and human trafficking.
10.2. We will consider relevant changes in legislation, guidance and recruitment industry practices when reviewing this policy.
10.3. We aim to improve our procedures for identifying risks, communicating expectations and responding to concerns.
10.4. We recognise that preventing exploitation requires ongoing awareness, cooperation and commitment from everyone involved in the recruitment process.
- Policy Review and Approval
This policy will be reviewed periodically and updated when necessary to reflect changes in legislation, business operations or identified risks.
BBS Recruitment remains committed to maintaining responsible recruitment practices and supporting the protection of workers’ rights.
Approved by: Company Directors
Company: BBS Recruitment
Policy Year: 2026
Review Date: October 2027
Contact BBS Recruitment
For questions or concerns relating to this policy, please contact:
BBS Recruitment
114 Mutton Lane
Potters Bar
Hertfordshire
EN6 2HE
Telephone: 01707 663777
Email: info@bbsrecruitment.uk
Website: www.bbsrecruitment.uk
BBS Recruitment — Committed to Ethical Recruitment, Fair Treatment and Protecting Workers’ Rights.
