Structure, business and supply chain
The Eligo Group of Companies is a modern, dynamic group operating in the contract and permanent recruitment sectors, incorporating the Eligo Recruitment, Eligo Security and Eligo Medical brands.
We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen. In that spirit although we are currently exempt from the requirements of the legislation, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This slavery and human trafficking statement addresses the steps taken by each of our Group of Companies, namely Eligo Medical Ltd, Eligo Recruitment Ltd, Eligo Security Ltd and Eligo Towers Ltd . This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement on behalf of all companies within the Eligo Group, as relevant. Our efforts against slavery and human trafficking complement our broader CSR Policy and our adoption of the Ethical Trading Initiative.
All Eligo Group Companies are headquartered in London, England. We provide recruitment services throughout Europe, including the United Kingdom. We do not produce, sell or supply goods of any sort. We provide recruitment services by sourcing candidates from across the world that we believe have the academic skills and professional experience to meet the needs of our clients. These candidates may either be placed by us becoming employees of our clients or in short-term temporary/longer-term contractor roles becoming either our employees or operating as self-employed contractors (“workers”) providing services to our clients via our companies. We have around 35 employees within our Group in addition to approximately 100 workers who are engaged through our supply chain. We source candidates in one of two ways. Either they respond to adverts we place on well-known industry “job boards” seeking candidates with specific job skills and experience or we contact candidates who have become known to us either through established business networking groups or who have achieved some form of recognition or publicity due to their skills and expertise.
Building on our existing CSR Policy and our commitment to the Ethical Trading Initiative, we have embraced the requirement to publish an annual slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year. This past financial year ending 31 March 2019, we took the following key steps to ensure slavery and human trafficking did not occur within our organisation or supply chain.
Slavery and human trafficking policies
Notably, we have begun to develop a Slavery and Human Trafficking Policy, which on completion will be found within our new Corporate Social Responsibility (CSR) Policy. We have also begun to develop a Supplier Code of Conduct. It will set out clear objectives for 1, 3 and 5 year slavery and human trafficking plans around the following themes:
• Relationships: Strengthening our supplier engagement process
• Feedback: Establishing grievance mechanisms and channels for individual worker feedback
• Knowledge: Improving our knowledge base by collecting relevant data and improving Candidate sourcing techniques
• Third party engagement: Building strategic alliances with independent organisations and other businesses/bodies within the recruitment industry
• Measurable change: Developing verifiable KPIs to measure progress
• Supplier collaboration: Encouraging workers to collaborate to address slavery and human trafficking issues
• Accountability: Establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking
Due diligence procedures
We understand that our biggest exposure to Modern Slavery is in our sourcing candidates and workers from out with the United Kingdom, where we have undertaken activity over the last decade to minimise the risk of Modern Slavery. Within these areas, new suppliers and candidates/workers are subject to due diligence checks in the form of ethical/compliance audits. Such audits are also regularly conducted for existing suppliers and candidates/workers, including those operating within the United Kingdom. These audits assess compliance with the Global Sourcing Principles and are, amongst other things, intended to identify any Modern Slavery practices. If issues are identified, appropriate investigative and remedial actions will be taken.
Identifying, assessing, and managing risk
We set out to identify the extent of any slavery and human trafficking in our supply chains by:
• Conducting a thorough check of all academic, professional and national identity documentation, including any bank account or financial details obtained
• Engaging with all new candidates and workers to assess whether they are being “manipulated” by any unknown third party
• Interviewing (usually via digital communication) candidates and workers to discuss their existing conditions and their right to live and work in the location where clients wish to place them
• Constantly updating and evolving our work practices to develop an improvement plan to address new and previously identified slavery and human trafficking issues
• Instituting an annual review questionnaire (from April 2020)for existing candidates and workers to understand their self-assessment of slavery and human trafficking issues, allowing us to better identify slavery and human trafficking issues as they develop over time and to collect candidate and worker-provided data to track improvement in their attitudes.
We have not thus far discovered any slavery and human trafficking in any part of our supply chain. However we recognize that as less dependence is made on candidates and workers coming from other parts of the European Union and more become accessible from India, China and other parts of the non-European world, there will be a greater exposure to opportunistic trafficking occurring.
Key performance indicators
In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:
• Staff training levels
• Number of slavery incidents reported in the supply chain
Training available to staff
A key part of our slavery and human trafficking strategy is to promote cultural change through training. We have not thus far offered training but in the 2019-2020 financial year we will:
• Offer online training modules on modern slavery to all staff
• Ensure all staff are aware of current United Kingdom Home Office guidance and advice
• Run internally or send staff on such training seminars as may seem appropriate
• Aim to start development of a dedicated training and resources webpage which individual candidates and workers in the supply chain will be able to access to learn about modern slavery and human trafficking, understand their rights and anonymously report any slavery and human trafficking issues in their workplace.
About this statement
This statement was prepared by Cadboll Business Consultancy applying a template provided by VinciWorks, a leading provider of compliance training to over 80,000 people around the world. VinciWorks released a free guide to compliance with the Modern slavery Act and a new online modern slavery course. To learn more please visit www.vinciworks.com/modernslavery.