1. Introduction

This statement highlights our commitment to ethical labour practices and transparency across all operations.

2. Organisational Structure and Business

Operations:

• Recruitment Services: Sourcing and placing contractors, interim professionals, and executives across multiple sectors.
• Consultancy Support: Specialist contractor expertise and advisory services to support workforce strategies.
• Talent Delivery: Providing seasoned contractor workforces for client projects.

Supply Chains:

• Recruitment Partners: Collaborating with staffing agencies, labour providers, and subcontractors.
• Service Providers: Engaging third-party suppliers for HR, compliance, and IT support.
• Business Operations: Procurement of office supplies, software, and services from global providers.

3. Policies Against Modern Slavery

• Code of Conduct: Sets out ethical standards, including zero tolerance for forced labour, child labour, or human trafficking.
• Supplier Code of Conduct: Requires suppliers and recruitment partners to adhere to labour laws, fair wages, and safe working conditions.
• Whistleblowing Policy: Provides secure and anonymous channels to report concerns via info@procontractdirect.com (mark correspondence “Attn: Whistleblowing Officer”).
• Recruitment Ethics Policy: Ensures transparent, ethical hiring practices and full verification of any third-party agencies.

4. Risk Assessment and Due Diligence

High-Risk Areas:

• Recruitment Supply Chains: Risks associated with migrant workers, temporary staff, or subcontractors in certain industries.
• Labour Providers: Overseas and high-volume staffing partners where oversight may be limited.
• Subcontracted Services: Facilities or ancillary services where compliance visibility is reduced.

Due Diligence Measures:

• Supplier Audits: Annual assessments of high-risk partners, including document reviews and spot checks.
• Contractual Clauses: Anti-slavery provisions built into contracts, with termination rights for non-compliance.
• Recruitment Vetting: Verification of agency licences, contracts, wage practices, and compliance with UK labour law.

5. Training and Awareness

Employees & Staff:

• Annual e-learning modules on identifying modern slavery risks (e.g., signs of exploitation or restricted movement).
• Targeted workshops for HR, compliance, and procurement teams.

Suppliers & Partners:

• Guidance on meeting our Supplier Code of Conduct.
• Collaboration with initiatives such as Stronger Together to improve ethical labour standards.

6. Effectiveness and Key Metrics

FY Year Progress:

• Audited 85% of high-risk recruitment partners, resolving 12 cases of non-compliance.
• Trained 100% of procurement and HR staff to recognise indicators of modern slavery.
• Investigated 3 whistleblowing reports, resulting in the termination of one supplier partnership.

Challenges:

• Limited visibility into tier-2 and tier-3 suppliers.
• Addressing this gap through the introduction of compliance monitoring and enhanced reporting tools.

7. Continuous Improvement

FY Next Year Goals:

• Extend audits to 100% of high-risk suppliers.
• Launch a supplier self-assessment portal for real-time compliance tracking.
• Partner with independent organisations to strengthen ethical sourcing practices.

Stakeholder Engagement:

• Join relevant labour and anti-trafficking coalitions to share best practices.
• Work closely with recruitment partners to adopt Gangmasters and Labour Abuse Authority (GLAA) standards.

8. Approval and Commitment

This statement was approved by the Board of Directors/Senior Leadership of Pro Contract Direct Limited on 06/04/2025. We remain fully dedicated to eradicating modern slavery in all its forms and will review and update this statement annually.

Contact for Concerns

Email: info@procontractdirect.com
Phone: 0203 983 7422