Tackling Modern Slavery Statement


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Tackling Modern Slavery Statement

This statement is made as part of HEADS Recruitment Ltd’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how HEADS Recruitment 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, and relates to the financial year Jan 2018 to Dec 2018. It was approved by the board of directors on 01/02/2018.

Patrick Ramsdale

Legal & Compliance Director

February 2018



HEADS Recruitment Ltd is a limited company operating in the recruitment sector. We provide introduction services and supply temporary workers in the Supply Chain Sectors.

HEADS Recruitment Ltd is part of the wider PROMAN group that includes HEADS Recruitment Ltd (Company Number 3443013), HEADS Engineering Ltd (Company Number 4163986), and PROMAN Recruitment Ltd (Company Number 9907561).

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. Some of our work-seekers are supplied via other businesses, which facilitate providing them to the eventual hiring company.

The hiring companies and the workers that we work with and supply are located within the UK .

Other relationships

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

  • The Freight Transport Association ( fta.co.uk )
  • The Gangmasters License Authority (gla.gov.uk )



HEADS Recruitment Ltd has a modern slavery policy available at : www.heads-uk.com/tackling-modern-slavery-policy/

In addition, HEADS Recruitment Ltd has the following policies which incorporate ethical standards for our staff [and our suppliers].

  • Anti-Bribery Policy
  • Ethical Trading Policy
    • Annual Policy development and review

HEADS Recruitment Ltd’s policies are established by our directors, based on advice from HR professionals, industry best practice and legal advice, and in consultation with the Recruitment and Employment Confederation. We review our policies annually or as needed to adapt to changes.



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.
  • We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.
  • 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 identified the following potential risks in our supply chain:

  • Sector risks, because there may be substantially different working practices between different sectors,
  • Business partnership risks, acknowledging that different relationships your business has may have different risks associated with them. This can involve a variety of factors including knowledge and familiarity with the other business’s working practices, the length of the relationship, and any due diligence (audits etc.) you have conducted.

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 require the businesses we work with to address modern slavery concerns in their policies.
  • 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.
  • We work with “Stronger Together”, “Gangmasters and Labour Abuse Authority (GLAA)” and the “Recruitment and Employment Confederation” in order to combat the risk of modern slavery and human trafficking.

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



As part of monitoring the performance of HEADS Recruitment Ltd we track the following general key performance indicators:

  • All operations staff completes annual refresher training and assessment of recruitment technical knowledge including our ‘tackling modern slavery’ process and procedures.
  • All complaints are acknowledged within 48 hours and investigated within 7 days.
  • Reports of possible incidents of Modern Slavery.

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of directors:

  • the level of modern slavery training and awareness amongst our staff

We carefully consider our indicators, in order to ensure that we do not put undue pressure on our employees that might increase the potential for risk.



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

  • Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
  • Our recruiters 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.