1: Opening statement from senior management
This statement is made on behalf of Empresaria Group plc and each of its subsidiaries (Group Company) (which together are referred to as the Empresaria, ‘we’, ‘us’ or ‘our’ throughout this statement).
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Empresaria’s slavery and human trafficking statement for the financial year ended 31 December 2021.
Empresaria is committed to preventing all forms of slavery, servitude, forced labour, debt bondage and human trafficking from occurring within its business and supply chain, and expects the same high standards from its suppliers.
Empresaria Group plc is a member of REC (the Recruitment and Employment Confederation) and APSCo (the Association of Professional Staffing Companies). Many of our Group Companies are also members of similar trade associations in the locations they operate from around the globe.
2: Structure of the organisation and supply chains
Empresaria is a global recruitment and staffing business.
Our brands operate in 19 different countries in Europe, the Americas and Asia Pacific. A full list of Group Companies and their locations can be found in our Annual Reports, which can be downloaded from our website at: https://www.empresaria.com/financial-information/company-reports.
In 2021, Empresaria had a global annual turnover of £258m. One of our Group Companies, headwaylogistic GmbH (Germany), also exceeded the threshold for modern slavery reporting in its own right.
Our supply chains are limited, being largely restricted to suppliers providing office supplies and services such as IT and payroll, to our Group Companies.
3: Policies on modern slavery
As part of our commitment to combating modern slavery, all staff across Empresaria are required to comply with our policies, including our:
Modern Slavery Policy;
Code of Conduct.
We expect our suppliers to adhere to our policies where applicable and have a zero-tolerance approach to non-compliance.
4: Due diligence processes
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have continued the following due diligence procedures:
identifying and assessing potential risk areas in our Group Companies;
identifying and assessing potential risk areas in our supply chains, where appropriate;
introducing preventative measures where high risks are identified;
mitigating the risk of slavery and human trafficking occurring in our supply chains;
protecting whistle blowers.
5: Risk assessment
Empresaria regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its business and supply chains.
The nature of our business means that we supply or introduce individuals to work for our clients. We undertake compliance checks on prospective workers to confirm their identity, proof of address, right to work and other appropriate checks. We also require our clients to provide a safe working environment for our workers.
Our consultants maintain contact with workers supplied to our clients throughout the length of their assignments to ensure their safety and allow them to raise any concerns.
Most of our businesses provide recruitment services in relation to highly qualified and skilled individuals. They are predominantly engaged as professionals and/or in clerical/office-based environments in sectors at low risk of modern slavery, such as IT and professional services. The majority of the locations in which we operate are at very low risk of modern slavery, for example the UK, US, Germany, Australia and New Zealand. We therefore consider that most of our businesses do not operate in high risk sectors or locations.
However, where our Group Companies do supply or introduce lower skilled individuals into higher risk sectors (such as manufacturing or hospitality), or where we operate in higher risk locations (such as India, Philippines, Malaysia or Thailand), we review our processes regularly and introduce preventative measures if appropriate.
To date, we have not identified any instances of modern slavery anywhere in Empresaria or in our supply chains and there have been no reported breaches of the Modern Slavery Act 2015.
6: Measuring effectiveness
Empresaria has a compliance team trained to assess our businesses and identify risks associated with failure to comply with legal and regulatory requirements, including risks associated with modern slavery both in the UK and internationally.
We have reviewed the effectiveness of the measures taken to date and are committed to continuous improvement in identifying and evaluating risks and developing measures to help prevent modern slavery and human trafficking in our business or supply chains.
Our compliance team is trained to assist our businesses in ensuring that modern slavery and human trafficking do not occur in our businesses or supply chains. All staff are expected to understand and follow the Modern Slavery Policy.
This helps to ensure that staff at all levels within each business are sufficiently aware of the likely indicators of modern slavery to help them identify possible instances and ensure that they know when and how to raise any concerns.
8: Further actions and sign-off
In 2021 we carried out the following steps:
all Group Companies were asked to provide a detailed analysis of their supply chain and assessment of risks to provide an overview of risk; we used the information collated to assess training needs and identify areas where further preventative measures could be implemented;
we continued to incorporate specific modern slavery provisions in our agreements with hirer clients as well as in our updated standard client terms;
we maintained a central policy hub where all staff across Empresaria can easily access all our policies, including the Empresaria Group’s Modern Slavery Policy, making it easy for us to update them when needed and notify staff of changes quickly;
we continued to develop training materials for our Group Companies tailored for the recruitment and staffing sector, and our businesses in particular.
Following our review of our actions, this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps:
continue to incorporate specific modern slavery provisions in our agreements with new hirer clients;
assess and where appropriate update training for key employees in our Group Companies;
continue to work together to improve awareness of the issue of modern slavery and ensure all staff are informed of their responsibilities;
review the additional safeguards and/or compliance checks we have put in place for our businesses operating in higher risk locations or sectors.
This statement was approved by the Board of Directors on 12 May 2022.
Chief Executive Officer
12 May 2022