Modern Slavery Policy

Policy Statement

Modern slavery is a crime and a violation of human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking (modern slavery), all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Full Circle Employment Agency Ltd (the Company) has a zero-tolerance approach to modern slavery within its business and supply chains.

This policy applies to all persons:

  • Working for the Company, or on our behalf, in any capacity, including employees at all levels, directors, officers, agency workers, volunteers and agents
  • Our contractors, external consultants, agencies and third-party representatives.

The Company is committed to:

  • Acting ethically and with integrity in all our business dealings and relationships.
  • Implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains and
  • Ensuring there is transparency in our approach to tackling modern slavery in our business and supply chains consistent with our obligations under the Modern Slavery Act 2015.

Identifying modern slavery:

Modern slavery may be found in:

  • Our business
  • Our supply chains
  • Our client’s business

There is a typical victim of modern slavery, some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a victim of modern slavery or human trafficking:

  • The person is not in possession of their own passport, identification or travel documents.
  • The person is acting as though they are being instructed or coached by someone else.
  • The person allows others to speak for them when spoken to directly.
  • The person is dropped off and collected from work.
  • The person is withdrawn or appears frightened.
  • The person does not seem to able to contact friends or family freely.
  • The person has limited social interaction or contact with people outside of their immediate environment.

The above list is not exhaustive. A person may display several indicators set out above, but they may not necessarily be a victim of slavery or trafficking.

Responsibility for the policy and compliance

  • The Board of Directors have overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations.
  • All Company staff whether permanent or temporary agency workers must comply with this policy.
  • All suppliers and clients must comply with this policy.

Reporting modern slavery

  • Company staff suppliers/clients must report any incidence or suspicion of at the earliest possible stage your manager or Company Director.
  • If you are a supplier or client, report it to your primary account manager or business contact.

Publication of this policy

  • This policy is available to all staff, suppliers and clients on the Company’s website.
  • In addition to this staff who attend our compulsory training courses will cover our Modern Slavery Policy alongside other policies.
  • The modern slavery topics covered are, Forced Labour and Bonded Labour, Human Trafficking, Child Slavery and Descent Based Slavery.

Breaches of this policy

  • Any Company staff who breaches this policy may face disciplinary action which could result in dismissal for misconduct or gross misconduct.
  • The relevant member of the Company may terminate its relationship with a supplier/client if it is in breach of this policy. Alternatively, the relevant member of the Company may elect to work with the supplier/client to resolve the issue.

Policy reviewed January 2019

Next review January 2020