Modern Slavery and Human Trafficking Policy
Policy Owner: Board of Directors
Effective Date: 6th June 2026
Review Date: 6th June 2027
Version: 2.0
Policy Statement
Bennett Staff Bureau is committed to conducting business ethically and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude, and exploitation in any form.
We recognise our responsibility to take effective measures to prevent modern slavery within our business operations and throughout our supply chains. We are committed to acting transparently and responsibly and to continually improving our practices to safeguard workers’ rights and dignity.
Scope
This policy applies to:
- All employees
- Directors
- Temporary and permanent workers
- Agency workers
- Contractors and consultants
- Suppliers and subcontractors
- Any other parties acting on behalf of Bennett Staff Bureau
- All individuals and organisations associated with Bennett Staff Bureau are expected to comply with the principles set out in this policy.
Our Commitment
Bennett Staff Bureau will:
- Maintain robust procedures to minimise the risk of modern slavery within our business and supply chains.
- Conduct business relationships with honesty, integrity, and respect for human rights.
- Comply with all applicable employment, labour, and anti-slavery legislation.
- Encourage openness and support anyone who raises genuine concerns regarding modern slavery.
- Take prompt and appropriate action where any incidents or risks are identified.
- Review and strengthen our processes on an ongoing basis to ensure continued effectiveness.
Recruitment and Worker Protection
As a recruitment business, we are committed to ensuring that:
- All workers are engaged voluntarily.
- Workers retain control of their own identification documents and personal belongings.
- No worker is required to pay recruitment fees or unlawful charges for obtaining employment.
- Workers receive lawful pay and working conditions.
- We verify the identity and right to work of workers in accordance with legal requirements.
- Any signs of exploitation, coercion, debt bondage, forced labour, or human trafficking are investigated immediately.
Supply Chain Due Diligence
We seek to reduce the risk of modern slavery by:
- Assessing suppliers and business partners where appropriate.
- Working with reputable organisations that share our commitment to ethical employment practices.
- Reviewing supplier compliance where concerns are identified.
- Taking action where suppliers fail to meet expected standards.
- Monitoring risks within sectors and geographical areas that may present a higher risk of modern slavery.
Training and Awareness
Bennett Staff Bureau provides training and awareness information to relevant staff to help them:
- Recognise the indicators of modern slavery and human trafficking.
- Understand reporting procedures.
- Identify potential risks within recruitment activities and supply chains.
- Support victims and report concern appropriately.
- This includes awareness materials produced by recognised organisations such as the Gangmasters and Labour Abuse Authority (GLAA)
Reporting Concerns
All employees, workers, suppliers, and other stakeholders are encouraged to report any concerns or suspicions relating to modern slavery, human trafficking, forced labour, or exploitation.
- Concerns should be reported to a Director of Bennett Staff Bureau at the earliest opportunity.
Reports will be:
- Treated seriously and confidentially where possible.
- Investigated promptly and fairly.
- Escalated to relevant authorities where necessary.
- Managed without retaliation against any individual who raises a concern in good faith.
Investigation and Remedial Action
Where evidence of modern slavery or human trafficking is identified, Bennett Staff Bureau may take action including:
- Conducting a formal investigation.
- Suspending or terminating supplier relationships.
- Reporting concerns to law enforcement agencies and relevant authorities.
- Supporting any affected workers where appropriate.
- Reviewing internal controls and procedures to prevent recurrence.
Monitoring and Performance
We monitor the effectiveness of this policy through:
- Staff training completion rates.
- Internal audits and compliance reviews.
- Spot checks and due diligence activities.
- Reported concerns and investigation outcomes.
- Supplier assessments where applicable.
The Board of Directors reviews these measures periodically to ensure that our controls remain effective and proportionate.
Related Policies
This policy should be read alongside the following:
- Corporate Social Responsibility Policy
- Whistleblowing Policy
- Anti-Bribery and Corruption Policy
- Equality and Diversity Policy
- Recruitment and Selection Policy
- Safeguarding Policy (where applicable)
Approval
The Board of Directors of Bennett Staff Bureau has approved this policy. It will be reviewed annually, or sooner if required by legislative or operational changes.
