We at Boston Hale recognise that modern slavery and human trafficking is an ongoing global issue. Working in the recruitment sector, we are constantly aware of the need for fair, ethical treatment of all, and pride ourselves on the integrity and transparency of our business relationships. We are therefore fully committed to ensuring that Boston Hale, and all suppliers it works with, are free from any forms of modern slavery and human trafficking.
Due Diligence Processes for Slavery and Human Trafficking
Our Own Business
Boston Hale prohibits the use of all forms of forced labour and any form of human trafficking. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with UK employment laws and a whistleblowing procedure in place which employees are encouraged to use to report any concerns.
As part of our own business we supply temporary personnel to a number of clients. In this respect we have established and audited procedures to ensure that those employees:-
1. have a right to work in the UK. This involves asking the individual direct to view their passport. A delay in providing the passport might indicate a modern slavery issue;
2. where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid; and
3. where we are responsible for such temporary personnel whilst they are employed on our client’s premises, they are free to leave their assignment on reasonable notice.
In addition, our employees are made aware of Boston Hale’s requirement for employees to support and uphold human rights principles and know that Boston Hale will not tolerate, engage in or support the use of, forced labour.
Our Supply Chain
Apart from the use of umbrella companies and candidates’ limited companies, Boston Hale has a small range of suppliers in terms of the general operations of the business. However, any companies, professional firms and/or suppliers that we have contact with, to the best of our knowledge, have no modern slavery or human trafficking taking place.
If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would consider terminating our relationship should we see no improvement in the way their business is conducted.
Risk and Compliance
Boston Hale has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its UK supply. As our core business is focused on the provision of recruitment services in respect of white-collar professionals (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high-risk sector.
Training and Performance Indicators
Given our view that Boston Hale’s exposure to modern slavery risk is limited, and the existing due diligence processes we already have in place as an organisation, except as noted above, we have not implemented any specific training of our UK employees or key performance indicators in relation to modern slavery and human trafficking during the previous financial year.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Boston Hale’s slavery and human trafficking statement for the current financial year.