Modern Slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking – all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

TBT Recruitment Ltd (the Company) has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all business dealings and relationships. We implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

This policy is informed by, and aligns with, the principles of the UK Modern Slavery Act 2015, even though the Company is not legally required to publish a statement under section 54 due to turnover being below the statutory threshold.

The Company is committed to legal compliance, acting ethically, and upholding human rights as set out by the ILO and UN Guiding Principles, namely:

No worker should be indebted or coerced to work
No worker should pay for a job
Every worker should have freedom of movement

We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude. We reserve the right to audit suppliers where there is reason to believe non-compliance with this policy, and to take remedial action where necessary. We also expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for the Company or on our behalf in any capacity including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives, and business partners.

Responsibility for the Policy

The Company Directors have overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under our control comply with it. The Directors have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.

Compliance with the Policy

The prevention, detection, and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your management as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issues or suspicion of modern slavery in any part of our business or in the supply chains of any supplier tier at the earliest possible stage.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with management immediately.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery, in whatever form, is or may be taking place in any part of our own business or in any part of our supply chain.

If you believe that you have suffered such treatment, you should inform management immediately.

Communication and Awareness of the Policy

Training on this policy, and on the risks our business faces from modern slavery in its supply chain, will be provided where required. Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. The Company will terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.