Pursuant to Section 54(1) of the Modern Slavery Act 2015, this statement sets out Phipps Cameron Recruitment’s commitment to combat the practice of modern slavery, forced labour and human trafficking. It is also to understand the potential modern slavery risks related to its business and implement steps aimed at ensuring no slavery or human trafficking takes place in its own business and its supply chains. The statement is PCR’s commitment to act ethically by taking steps within its direct structures and wider sphere of influence to ensure that modern slavery, as set out in the Act, is not taking place.

Organisational Structure

Phipps Cameron Recruitment Limited (“the Company”) is a specialist recruitment consultancy.

Our Supply Chain

  • We are a provider of recruitment services and we consider our supply chain to be relatively simple.
  • We work with a small range of suppliers who provide goods and services across a number of different categories, such as IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain.
  • Having performed a risk assessment of our supply chain we consider that there is a relatively low risk of labour exploitation or other forms of slavery and human trafficking occurring within it. Nevertheless, we are committed to preventing these practices from occurring within both our business and supply chain which is demonstrated by our policies and due diligence procedures.

Relevant policies

PCR operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • PCR Anti-Slavery Policy
  • Whistleblowing Policy: PCR encourages all workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of PCR. The whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation
  • Employee Code of Conduct: The code makes clear to employees the actions and behaviour expected of them when representing the Company.
  • Our suppliers are required to comply with the PCR Employee Code of Conduct (which also applies to all employees of the Company) and with the PCR Supplier Code of Conduct.

These policies reflect our commitment to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our business and UK/EU supply chain.

Due Diligence

Our Company

The Company prohibits the use of all forms of forced labour and any form of human trafficking. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with UK & EU employment laws and a whistleblowing policy which employees are encouraged to follow to report any concerns.  As part of our own business we supply temporary personnel to a number of clients. In this respect we have established and audited procedures to ensure that those employees:-

  • Have a right to work in the UK. This involves asking the individual directly to view their passport. A delay in providing the passport might indicate a modern slavery issue;
  • Where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid; and
  • Where we are responsible for such temporary personnel whilst they are employed on our client’s premises, they are free to leave their assignment on reasonable notice.
  • In addition, our employees, through the Employee Code of Conduct, are made aware of the Company’s requirement for employees to support and uphold human rights principles and know that PCR will not tolerate, engage in or support the use of, forced labour.

If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would terminate our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

  • identify and assess potential risk areas in our UK/EU supply chain;
  • mitigate the risk of slavery and human trafficking occurring in the supply chain;
  • monitor potential risk areas in the supply chain; and
  • provide adequate protection to whistle blowers.

Risk and Compliance

The Company has reviewed suppliers and assessed whether any particular risks of slavery or human trafficking arise. It does not consider that key relationships with professional or business services suppliers give rise to material risks in this area. Risk may have the potential to arise in relation to internal facilities management, catering and the supply of office electronic equipment. Risk is managed through the use of suppliers who are considered to be reputable, and it has been specifically requested that all material regular suppliers confirm that their own business activities do not involve slavery or human trafficking. This evaluation process will continue on an annual basis.

Due Diligence – Steps taken by the Company this year

(1) Management responsibility and general awareness

  • Agreed management responsibility for this statement and the PCR Anti-Slavery Policy has received unanimous endorsement from the Board
  • Raised general organisational awareness
  • Reported progress to the executive management team and the Board
  • Efforts made to raise awareness of this published statement

(2) Risk assessment

  • Undertaken assessments using legal, risk and procurement teams to determine risk exposure
  • Included the Modern Slavery Act 2015 within PCR’s statutory and regulatory compliance risk assessment procedures to ensure the risk continues to be flagged, assessed and appropriately addressed
  • Asked suppliers to confirm their compliance with the Act during the commercial due diligence process

(3) Risk mitigation

PCR seeks to impose adequate and robust contractual provisions relating to modern slavery or human trafficking compliance by applicable suppliers doing business with the Company. PCR:

  • Acts promptly where a compliance breach has been identified or flagged
  • Continues to feedback lessons learnt into the compliance risk management process

Steps to take during 2024

(1) Risk assessment

  • Commence a review exercise of this policy against PCR’ activities in relation to any newly acquired entity that may be incorporated within the Company. Generally, continuing to establish whether the approach taken by the Company follows emerging best practice by:
  • Assessing and interpreting any recent or emerging case law and best practice;
  • Benchmarking activities against statements and action plans undertaken by similar organisations;
  • Re-evaluating the risk of non-compliance as part of the cyclical compliance risk register assessment
  • Continuing to ask suppliers to confirm they are compliant when conducting commercial due diligence

(2) Risk mitigation

  • Act promptly where a compliance breach has been identified or flagged
  • Continue to feedback lessons learnt into the compliance risk management process

(3) Training

  • Online training of staff so they are kept up to date

Awareness-raising programme

As well as training staff, PCR has raised awareness of modern slavery issues by producing an PCR Anti-Slavery Policy that is introduced to staff as part of the induction process and made available on the Company’s shared-drive thereafter.

The PCR Anti-Slavery Policy explains to staff:

  • The basic principles of the Modern Slavery Act 2015;
  • How employees can identify and prevent slavery and human trafficking; and
  • What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Organisation

Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s statement for the year ending December 2023.

This statement has been approved by PCR’s Board of Directors, who will review and update it annually:

  • Giles Cameron ~ Co-Founder/Director  &  Charles Phipps ~ Co-Founder/Director