At PageGroup we believe in the importance of equality in the workplace. Being a responsible corporate citizen is not only the right thing to do, it is good for the long term viability of our business. We have an established Employee Code of Conduct which details the standards by which we operate. We expect these same high standards from our suppliers. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.
We have developed a PageGroup Supplier Code of Conduct which makes it clear that we expect the staff employed by our suppliers, whether permanent or temporary, to have the same basic right to be treated with respect and dignity at work as our own employees. We believe employment should be chosen. There must be no forced, bonded or involuntary prison labour. Supplier employees must not be required to lodge monies or identity papers in order to work and must be free to leave employment after the giving of reasonable notice.
We are publishing this statement to explain the work we have completed to date to combat modern slavery within our business and the steps we intend to take over the coming year.
We are a global specialist recruitment consultancy, the parent company of the PageGroup plc group of companies who trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE and PAGE PERSONNEL (Group). The Group has over 6,000 employees worldwide, operating in 36 countries, with a global annual revenue of over £1.1bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.
Our UK Supply Chain
As a provider of recruitment services we do not have a particularly long or complex supply chain. In the UK we work with a small range of suppliers who provide goods and services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain, and do not feel that it is particularly susceptible to labour exploitation or other forms of slavery and human trafficking. Nevertheless, we are committed to preventing these practices from occurring within both our business and our supply chain, which is demonstrated by our policies and due diligence procedures as outlined below.
Our Policy on Modern Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in our business. Our UK suppliers are required to comply with our PageGroup Supplier Code of Conduct and Employee Code of Conduct which reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our UK supply chain.
Due Diligence Processes for Slavery and Human Trafficking
Our Own Business
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:-
- 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;
- 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
- 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, through the Employee Code of Conduct, are made aware of PageGroup’s requirement for employees to support and uphold human rights principles and know that PageGroup will not tolerate, engage in or support the use of, forced labour.
Our Supply Chain
As part of our initiative to identify, monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, we have undertaken the following due diligence procedures:-
(a) we have commenced the mapping of suppliers who provide goods and services to our UK business to identify those suppliers whose goods or services are heavily dependent on the provision of people;
(b) we have started to assess those suppliers in the UK supply chain who we believe are in a high risk area, and have written to each such supplier to note our commitment to transparency and combatting modern slavery within our own organisation and our similar expectation from suppliers of goods and services to us. We have sent to these suppliers the PageGroup Supplier Code of Conduct and requested a signed confirmation from those suppliers that they adhere to our required standards; and
(c) we have reserved the right with our suppliers to request access to their facilities for members of our Internal Audit Team to check compliance with the PageGroup Supplier Code of Conduct. Such on-site audits would also help us to identify whether a supplier was engaged in unethical practices, which might include forced labour or other forms of modern slavery.
We will also follow this process with those further suppliers identified as we complete our supplier mapping work, and with new suppliers. We will include appropriate terms in our agreements which place an obligation on suppliers to comply with the Modern Slavery Act 2015. 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.
This approach is designed to:
- identify and assess potential risk areas in our UK supply chain;
- mitigate the risk of slavery and human trafficking occurring in the supply chain;
- monitor potential risk areas in the supply chain; and
- provide adequate protection to whistle blowers.
Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its UK supply chain through its Internal Audit Function in combination with the Group Procurement Team. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (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. This evaluation process will continue on an annual basis.
Training and Performance Indicators
Given our view that PageGroup's exposure to modern slavery risk is limited, and the existing due diligence processes we already have in place as an organisation, we have not implemented any specific training or key performance indicators in relation to modern slavery and human trafficking during the previous financial year.
Following a review of the effectiveness of the steps we have taken so far this financial year to prevent modern slavery or human trafficking occurring in our business and UK supply chain we intend to take the following further steps to combat slavery and human trafficking during the course of the 2017 financial year:
- to complete the mapping of our UK suppliers;
- include appropriate anti-modern slavery terms in our agreements with suppliers;
- continuing to raise awareness with our key teams provided through training to ensure a high level of understanding of the risks of modern slavery and so they are aware of what to look out for in respect of modern slavery; and
- identify how best to map the supply chains of our overseas businesses.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2016.
Steve Ingham, Chief Executive Officer
Date: 8 June 2017