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Modern Slavery Policy

1. Site Operative Solutions Ltd is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.

2. Site Operative Solutions Ltd is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

3. Site Operative Solutions Ltd provides appropriate training and awareness information for all of its staff.

In particular:

  • All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

4. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to the Managing Director.

5. Reports surrounding these issues are taken extremely seriously by our board of directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

  • Working with the appropriate organisations to improve standards
  • Passing details to appropriate law enforcement bodies.

6. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:

  • The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
  • The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
  • The level of modern slavery training and awareness amongst our staff.

7. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

8. We would also recommend reading this in conjunction with our other policies, including our:

  • Diversity and Equality Policy
  • Equal Opportunities Policy
  • Anti-bribery / corruption policy, and
  • Whistle-blowing policy.

This policy was adopted in 2015 after being agreed by our board of directors. It is reviewed annually.


Modern Slavery Statement

This statement is made as part of Site Operative Solutions Ltd’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Site Operative Solutions Ltd operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act, relates to the financial year October 2018 to September 2019. It was approved by the board of directors on 1st October 2018.

Ray Higgins

Managing Director


1. Our Business

Site Operative Solutions Ltd is a limited company operating in the recruitment sector. We supply temporary workers in the Rail, Utilities, Construction, Energy sectors.

Site Operative Solutions Ltd is an independent business.

1.1 Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies.

1.2 Other relationships

As part of our business, we also work with the following organisations:

sector-specific trade union

sector-specific trade unions• sector-specific professional and regulatory bodies

sector-specific industry bodies

the Recruitment and Employment Confederation (www.rec.uk.com) and the Institute of Recruitment Professionals (www.rec-irp.uk.com)


2. Our Policies

Site Operative Solutions Ltd has the following policies which incorporate ethical standards for our staff and our suppliers. 

  • Data Protection Policy
  • Data Protection Policy
  • Privacy Policy
  • Diversity and Equality Policy
  • Drug and Alcohol Policy
  • Environmental Policy
  • Quality Policy
  • Equal Opportunity Policy
  • Ethical Policy
  • Health and Safety Policy

2.1 Policy Development & Review

Site Operative Solutions Ltd’s policies are established by our, based on advice from HR professionals, industry best practice and legal advice, and in consultation with the Shareholders. We review our policies annually, or as needed to adapt to changes.


3. Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

  • When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
  • When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
  • We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.

Additionally, we have taken the following steps to minimise the possibility of any problems:

  • We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
  • We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
  • Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
  • We ensure that all of our suppliers are members of appropriate industry bodies and working groups.

Our staff are encouraged to bring any concerns they have to the attention of management.


4. Our Performance

As part of monitoring the performance of Site Operative Solutions Ltd, we have established the following key performance indicators, which are regularly assessed by our board of directors:

  • the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
  • the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements• the percentage of candidates supplied from audited businesses / our preferred supplier list
  • the effectiveness of enforcement against suppliers who breach policies
  • the amount of time spent on audits, re-audits, spot checks, and related due diligence
  • the level of modern slavery training and awareness amongst our staff

We benchmark our indicators against industry best-practice in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.


5. Our Training

All of our staff receive training and support that is appropriate to their role. In particular:

  • Our leadership team and senior supply chain managers receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
  • Our recruiters, HR personnel, and staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
  • All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this, our staff are encouraged to discuss any concerns that they have.

Training is refreshed annually.

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