Modern Day Slavery

Organisation

This statement applies to Privilege HR trading as Privilege People Hub 365 (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the calendar year 2023.

The labour supplied to the Organisation in pursuance of its operation is carried out in Liverpool, United Kingdom.

Definitions

The Organisation considers that modern slavery encompasses:
 human trafficking
 forced work, through mental or physical threat
 being owned or controlled by an employer through mental or physical abuse of the threat of abuse
 being dehumanised, treated as a commodity or being bought or sold as property
 being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation
strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, and in many cases exceeds those minimums in relation to its employees.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to supplying workforce services to businesses within the United Kingdom.

Potential exposure

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited.

Impact of COVID-19

The Organisation’s modern slavery risks were subject to the same monitoring procedures during the pandemic as at all other times.

Steps

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
 reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
 measures in place to identify and assess the potential risks in its supply chains
 undertaking impact assessments of its services upon potential instances of slavery
 any actions taken to embed a zero tolerance policy towards modern slavery
 any training provided to staff on modern slavery.

Key performance indicators

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

Policies

The Organisation has the following policies which further define its stance on modern slavery; recruitment policy, environmental policy.

Slavery Compliance Officer

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: March 2023
Print name: Peter Waller-Flynn

Job Title: Managing Director
Date: 16/03/2023