1. Policy Statement

HT Recruit Ltd is committed to preventing modern slavery, human trafficking, forced labour and exploitation in all areas of our business operations. We uphold the highest standards of ethics, integrity and transparency and expect the same from all clients, contractors, suppliers and partners.

We have a zero‑tolerance approach to modern slavery and will not knowingly engage with any organisation involved in such practices.

2. Purpose of This Policy

This policy aims to:

• Prevent modern slavery and human trafficking within our business and supply chain

• Ensure employees understand their responsibilities

• Demonstrate compliance with the Modern Slavery Act 2015

• Protect candidates, contractors and temporary workers

• Promote ethical recruitment practices

3. Scope

This policy applies to:

• Directors

• Employees

• Temporary workers

• Contractors

• Umbrella companies

• Payroll providers

• Clients

• Suppliers

• Any person acting on behalf of HT Recruit Ltd

4. Understanding Modern Slavery

Modern slavery includes:

• Forced labour

• Human trafficking

• Debt bondage

• Exploitation of vulnerable individuals

• Coercion or control over a person for labour or services

• Withholding passports or identity documents

• Paying below lawful minimum wage

• Restricting freedom of movement

5. Recruitment‑Specific Risks

As a recruitment business, HT Recruit Ltd recognises potential risk areas:

• Temporary worker supply chains

• Umbrella companies

• Payroll providers

• Contractors operating through third parties

• Clients requesting unusual payment arrangements

• Workers being pressured into unfair contracts

• Workers being paid into accounts not belonging to them

We will not participate in any arrangement that may enable exploitation.

6. Due Diligence

HT Recruit Ltd conducts reasonable checks on:

• Candidates

• Contractors

• Umbrella companies

• Payroll providers

• Clients

• Suppliers

Checks may include:

• Identity verification

• Right to Work documentation

• Confirmation of payment arrangements

• Review of umbrella compliance

• Supplier risk assessment

7. Employee Responsibilities

All employees must:

• Act ethically and with integrity

• Report concerns immediately

• Follow company procedures

• Complete training where required

• Ensure candidates are treated fairly and lawfully

8. Supplier & Client Expectations

HT Recruit Ltd expects all clients and suppliers to:

• Comply with the Modern Slavery Act

• Maintain ethical labour practices

• Ensure safe working conditions

• Pay workers fairly and legally

• Avoid any form of exploitation

We reserve the right to terminate relationships with any party found to be involved in modern slavery.

9. Reporting Concerns

Any employee, contractor or supplier who suspects modern slavery must report concerns immediately to a Director.

Reports will be:

• Taken seriously

• Investigated promptly

• Handled confidentially wherever possible

• Escalated to authorities if required

No individual will suffer detriment for raising a genuine concern in good faith.

10. Training & Awareness

HT Recruit Ltd will provide training where appropriate to ensure employees understand:

• What modern slavery is

• How to identify warning signs

• How to report concerns

• How to conduct ethical recruitment

11. Monitoring & Review

This policy will be reviewed annually and updated to reflect:

• Legislative changes

• Operational changes

• Identified risks

• Industry best practice

12. Queries

If you have questions about this Policy:

Email: [email protected]  Website: https://www.htrecruit.co.uk Phone: (+44)203 758 8602 Address: 1 Coldbath Square, London EC1R 5HL