Modern Slavery and Human Trafficking Statement

1st November 2017

Our Commitment
Our commitment to responsible business is reflected in how we run our company. We are committed to implementing and enforcing our Modern Slavery and Human Trafficking Policy. We both monitor and work to improve the systems we have put in place to ensure that modern slavery does not take place anywhere in our business and no one with whom we do business benefits from or in any way contributes to Modern Slavery.

It is the responsibility of all at V&P Global Ltd to ensure compliance with our Policy. We work to ensure that all who work at V&P Global Ltd fully understand how we strive to improve the impact of our Policy. We have in place mechanisms to deal with any concerns or breaches of the Policy including arrangements for reports to be made anonymously by telephone or over the web, details of which are contained in our Policy. Confidentiality will be protected to the fullest extent possible.

We expect all who do business with us, including those in our supply chain, to have the same commitment, as we do, to our Policy.

Introduction
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) on behalf of V&P Global Ltd, which is incorporated in England & Wales (Reg. No 06858428) and provides recruitment services in the UK, Europe, the Middle East and Asia.

Given that our business is the provision of professional services, we consider that the risk of Modern Slavery within our business or our supply chain to be low, but we are conscious that Modern Slavery occurs in different forms throughout the world, including in the UK.

We have formed a working group to consider what actions we would take to ensure compliance with the Act. The primary focus of the group is the business which is managed from the London office. It is intended that that the group will progressively build, each year, on the work which has been done in prior years.

One of the first tasks undertaken by the working group was to assist with the drafting of the Policy. This sets out our zero-tolerance to Modern Slavery and identifies how any concerns can be reported. The Policy was adopted in October 2017. All who work for V&P Global Ltd were informed of its adoption.

Supply chain – UK business
We have developed a risk- based approach to the assessment of the possibility that Modern Slavery exists within V&P Global Ltd’s supply chain. Those undertaking the assessment have reviewed all suppliers. For each supplier information has been collected as to the identity of the actual supplier, the services or goods provided to V&P Global Ltd’s business, and the contract value. When undertaking the assessment a number of factors were then considered which are broadly (1) location where the service or goods are supplied, (2) the industry sector from which the services or goods is provided, and (3) the labour practices specific to the industry and the location from which the particular services or goods are supplied. Labour practices reviewed included consideration of issues relating to recruitment (e.g. whether workers were charged excessive recruitment fees or fraudulently charged for health checks), during employment( e.g. underpayment or withholding passports), and termination (e.g. worker’s visa tied to employer or a requirement on the worker to pay a deposit by way of runaway insurance). The result of the exercise was that all of our suppliers were assessed as low risk.

From 1 January 2017 any new arrangement with a supplier will included a commitment by the supplier to comply with the Policy.

Staff Training
Our focus has been on raising awareness as to the obligations contained in the Act and the presence of slavery and human trafficking throughout the world. Information regarding what Modern Slavery is and how it may impact our business has been provided to all who work for V&P Global Ltd.

Frank Varela
CEO

Date 1st November 2017

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Modern Slavery and Human Trafficking Policy

 

 

Modern Slavery comes in various forms but in all forms, it has the common feature of one person depriving another of his or her liberty in order to exploit that person for commercial or personal gain.

 

The term Modern Slavery is also used to denote human trafficking which includes the acts of recruiting, transporting, transferring, harbouring or receiving a person, through any coercive means for the purpose of exploitation.

 

In all its forms, Modern Slavery is a violation of human rights and is illegal, but we as a company are conscious that it continues to occur across the world, including in the UK. It is important to us that we are doing everything that we can where ever we operate.

 

Our goal is to implement systems which will ensure that Modern Slavery is not taking place anywhere in our business and that those with whom we do business never benefit from or in any way contribute to Modern Slavery.

 

The objective of the systems which are being put in place is to ensure that everyone who works for and does business with us upholds and acts in accordance with the same principles.

 

In particular, everyone who works for and does business with us must avoid any activity that might amount to, or lead to, a breach of this Policy. This Policy applies to all who work at V&P Global Ltd and anyone who has a business relationship with V&P Global Ltd.

 

We endeavour to communicate our Policy and the means to report breaches to all suppliers, contractors and others with whom we do business at the outset of any business relationship and remind them of our approach, when appropriate.

 

We may terminate our relationship with any person or organisation who does not comply with this Policy. A breach of this Policy by an employee of V&P Global Ltd will be considered under the company’s misconduct procedures and, if a serious breach, could be a treated as gross misconduct, which might result in dismissal without notice.

Reporting breaches of this Policy It is the responsibility of all of us to detect and report any incident of Modem Slavery.

 

Any suspicion of Modern Slavery or other issues which could be a breach of the Policy should be raised at the earliest opportunity. If you are unsure whether a particular act or treatment by a V&P Global Ltd employee or supplier might constitute Modern Slavery, please raise it for further consideration by the company.

 

Reports should be made to the CEO, Frank Varela fvarela@vandpglobal.com