MPI Limited and its parent company MPI (Herts) Limited (MPI) are committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses. MPI is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
All staff within MPI are expected to comply with all laws, act in accordance with MPI’s Modern Slavery Policy and act with integrity and honesty. Modern slavery forms part of the training package undertaken by new employees and training and information is provided to members of staff annually and recorded, in particular:
· Our senior leadership team receive detailed briefings in identifying and resolving concerns around modern slavery and human trafficking.
· All staff members 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.
All MPI employees have access to dedicated channels through which they may voice concerns through local and central reporting mechanisms. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to the Quality and Sustainability Director. Reports surrounding these issues are taken extremely seriously by the senior leadership team, who are committed to ensuring that any investigations are prompt and effective. MPI is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially, professionally and without fear of retaliation.
We monitor our risks in this area through the use of relevant key performance indicators, including:
· The number of suppliers who provide their own modern slavery statements,
· The effectiveness of enforcement against suppliers who breach policies,
· The amount of time spent on audits and related due diligence, and
· The level of modern slavery awareness amongst our staff.
As part of our initiative to identify and mitigate risk, the following potential risk areas have been identified:
1. Provision of temporary workers to clients
Risk: Temporary workers placed with clients may be enslaved or human trafficked individuals.
Modern day slavery checks are interwoven throughout MPI’s end-to-end recruitment business practices. At the outset of the recruitment process, our recruitment team ensure strict compliance checks are carried for all candidates.
We verify the identity of each worker and their right to work before supply commences. Copies of forms of identity such as passports are taken and the originals are not retained by MPI, only the copies are in electronic stored documents on our candidate database.
Audits are carried out throughout the year of entries on the database to identify errors, anomalies and inconsistencies in candidate and assignee records.
Employment agencies are prohibited by law, from charging or seeking to charge work-seekers to find or seek work for them and MPI complies with this. Individuals are not subject to hidden payments of any form.
All employees and assigned contract workers are treated fairly and a contract for or of services is entered into at will by both parties.
Payments are agreed before the assignment commences. Wages are not unfairly held and made weekly a week in arrears to the assigned worker’s personal or business bank account and monthly for employees.
A flag up system highlights requests made for monies to be paid into a different account, enabling checks to be carried to eliminate the risk of bonded labour having no access to their earnings.
All payment mechanisms comply with HMRC legislation in relation to tax, National Insurance and pension contributions.
Our representatives look out for signs of modern slavery within the teams when undertaking onsite visits and safety tours, such as bruises and cuts, mistrust of authorities, controlled movements, poor communication and other signs of working against their will.
All employees received a modern slavery briefing in July 2023 that reiterated what it is, the signs to look out for within the business and industries we provide labour to, the checks that need to be undertaken and how to report suspected modern slavery activities.
2. Suppliers that make up MPI’s supply chain
The use of suppliers that contravene the Modern Slavery Act 2015.
As part of our commitment to identify and eradicate slavery and human trafficking, we also have in place a process to undertake due diligence on our supply chain network including second tier recruitment agencies where utilised, to ensure compliance with legislative obligations. All suppliers are required to complete and return a supplier appraisal questionnaire that summarises their adherence to the Modern Slavery Act 2015. If our due diligence reveals any issues, we are committed to taking appropriate action, including but not limited to:
· Working with the appropriate organisations to improve standards,
· Removing that organisation from our preferred supplier list,
· Passing details to appropriate law enforcement bodies.
Our effectiveness in combating slavery and human trafficking
MPI has not received any reports of instances of modern slavery over the past financial year.
· MPI will continue to raise awareness of modern slavery and of the need for proper due diligence to be applied by all employees, suppliers and customers throughout the coming year and formally re-brief all employees within the next 12 months.
· Modern slavery will continue to be included within the induction process for all new employees.
· MPI shall continue to conduct regular audits of its candidate registration and vacancy fulfilment processes to ensure that only eligible workers are assigned to clients.
· Audits of the candidate database will continue to take place throughout the year.
· MPI will assess new suppliers to ensure that they adhere to the Modern Slavery Act 2015.
· MPI shall continue to monitor and promptly investigate any reports of modern slavery or human trafficking.
Issue: 8 Approved by: E. Pearson Chairperson
Reviewed: 06 July 2023 Edward Pearson