This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that HFG has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses ‘slavery, servitude, human trafficking and forced labour’; High Finance (UK) Ltd and its subsidiaries (together ‘HFG’) have a zero tolerance approach to any form of modern slavery within our organisation whether direct or indirect. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain
High finance (UK) Ltd is a privately owned limited company providing permanent and temporary staffing services to our clients operating in both the public and private sector within the insurance industry.
HFG undertakes checks in relation to all candidates who we introduce to clients to ensure we clearly establish their identity. For individuals this includes checking documentation such as their passport or visa (if applicable) to verify their right to work. For Limited companies this includes checking documentation their incorporation, directorship and insurance status.
Our Supply Chains
Given the industry in which we operate, we do not have an extensive supply chain network. Our supply chains include, amongst others: office supplies; IT hardware, software and services; cleaning services; office maintenance services and professional services such as those provided by HFG’s external finance and payroll provider.
In addition to the above, as part of our contract with suppliers, we now require that they confirm to us that:
1.They have taken steps to eradicate modern slavery within their business
2.They hold their own suppliers to account over modern slavery
3.They pay their employees at least the national minimum wage / national living wage (as appropriate)
4.We may terminate the contract at any time should any instances of modern slavery come to light
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
Anti-slavery policy.This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.
Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
Apsco Code of conduct.This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.http://www.apsco.org/about-us/codes-of-conduct.aspx
Corporate social responsibility policy. This policy demonstrates our commitment to acting in an ethical and socially responsible way in order to meet the expectations of our candidates, clients, employees, the community and environment.
Due Diligence Process for Slavery and Human Trafficking
HFG ensure strict compliance checks are carried for all candidates it supplies. We verify the identity of each worker and his or her right to work before supply commences.
As part of our commitment to identify and eradicate slavery and human trafficking, we are undertaking due diligence on our supply chains to ensure compliance with legislative obligations and will continue and evolve this process in future years.
Risk Analysis and Next Steps
We determined that we are in low risk industries characterised by low volume high value work activity and following the publication of the Modern Slavery Act, we have conducted a review of all key suppliers to identify those operating in countries of higher risk of forced labour. This initial review identified that the vast majority of HFG suppliers are located in very low risk areas, with most of those working in sectors that are not considered to be high-risk sectors.
Key performance indicators and effectiveness.
We will know the effectiveness of the steps we are taking to ensure slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, client, candidates, members of the public or law enforcement agencies to indicate that modern slavery practises have been identified.
All HFG staff are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. We have undertaken to review our policies and procedures to ensure our employees have access to any additional information and support they may require with regard to human trafficking, forced labour, servitude and slavery. Further training will be provided as required, which is an area that remains under review.
Group Commercial Director
High Finance (UK) Ltd