Modern Day Slavery Statement 2022/23
Slavery, servitude, forced labour and human trafficking (modern slavery) are issues of increasing global concern, affecting all sectors, regions and economies. Modern slavery is fundamentally unacceptable within our business and the supply chain, and is a key focus in our overall approach to business and human rights.
Nexus Workforce Limited are committed to respecting, protecting and championing the human rights of all those who come into contact with our operations, including employees, temporary workers, customers and local communities. We accept our responsibility to support transparency and honesty; to find and resolve problems, and to work with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery.
This statement has been published in accordance with the Modern Slavery Act (2015). It sets out the steps Nexus People will take during the year, ending 30th April 2022 to prevent modern slavery in our business operations and supply chains.
About Nexus People
Nexus People are a temporary recruitment agency offering flexible recruitment solutions across various sectors within the logistics industry supporting staffing requirements across, warehousing & Industrial, HGV driving, home delivery logistics and administration and support.
Our largest peak period of recruitment runs from September to December whereby we require considerable additional resource for the seasonal Christmas period aligned with the retail & logistics industry. Other peak periods of the year are at Easter and the summer months where we see an increase in the need for temporary labour supply within our client operations.
Business Structure & Supply Chains
Nexus People is based in the UK with a head office in Brighouse, West Yorkshire. The business mainly operates an “on-site” solution, whereby we base our skilled account managers on our client’s sites to provide 24-hour service. We have additional offices in Trafford Park, Glasgow, Doncaster, Leicester and Mansfield.
The business recruit flexible employees from various sources to supply to our end clients.
Once a candidate becomes an employee of Nexus People, we provide the employee with a temporary work assignment at one of our client sites across the UK. We supply and employ approximately 5,000 temporary workers a week at any one time.
Our company terms of business guarantee an employee’s weekly pay regardless if we have been paid by the end client within the supply chain. We always act ethically and will not withhold a payment to an employee or supplying business unless we suspect fraudulent or suspicious activity.
The business work in partnership with our clients and suppliers to ensure our rate structure is competitive and at market standard within the UK. Rates are determined based on the job availability within the area, local competitors and industry standards factoring all aspects of a charge rate (e.g. ENI, Holiday Pay, Auto Enrolment, Levy, Margin). We always pay the national living wage.
Policies & Contractual Controls
Nexus People has several policies and controls which govern our modern slavery statement, of which all employees, suppliers and business partners adhere to. Set policies are included in our employee handbook which is provided to all new starters on week one of starting an assignment or employment with us. Our business policies are also available for permanent employees on our internal HR portal for all to view.
Nexus People acts to embed a culture of trust where workers are valued and treated with dignity and respect and can raise issues without fear of retribution.
We have the following policies in place to prevent modern slavery:-
- Anti-Slavery and Human Trafficking Policy
- Recruiter Compliance Principles (Permanent employees)
- Whistle Blowing Procedure, Equality Act opportunities and employee code of conduct (Employee Handbook)
- Terms of Business, Supplier Contracts and Client Agreements (Containing specific clauses relating to anti-slavery and human trafficking which interlink with our policy)
Nexus Workforce Limited are also members of Stronger Together, a business-led multi-stakeholder initiative working to reduce modern slavery particularly hidden forced labour, labour trafficking and other third-party exploitation of workers. We use their expertise and resources to support us in implementing policy and control within our operations.
Due Diligence & Risk Assessment
Nexus People recognises that there is a risk of modern slavery in any area of our business where there is:
- Migrant Labour (country to country or within a country)
- High presence of refugees and European workers. (Further impact by the new immigration system Jan 2021)
- Women workers
- Outsourced labour supply functions (2nd Tier suppliers)
Nexus People’s Directors are responsible for ensuring Nexus People meets its human rights responsibilities. We continue to monitor, evaluate and address any risk of modern slavery through the following methods:
- During the recruitment process, our temporary employees are taken through an induction which includes information, guidance and a video on modern slavery, including the importance of reporting any suspicion to team leader and managers
- We display Modern Slavery posters either branded by the GLAA, Stronger Together or Nexus people across all branches and on-site warehouses (including in private areas such as toilets, canteens and locker rooms) to raise awareness
- We promote through all operations a trusted communication method which links directly to our HR department through our management team
- Our HR department hold regular “HR Surgeries” at each of
- Our client warehouse locations which allow individuals to speak to HR on a confidential basis, at a time that suits them, raising any issues or concerns to improve worker welfare. In addition to this, the team also do floor walk arounds which allow workers to speak to HR on an informal basis, building a relationship with each worker to encourage day to day discussions
- On a monthly basis, we run a HR report that determines where we have duplications in our employee records. We particularly look for where workers are sharing living arrangements, telephone numbers, and next of kin details. Our sites are also tasked to detect multiple occupancy during a registration or interview session with workers and highlight this to the HR department immediately. If we determine an employee to be “high risk” we conduct a Modern Slavery Risk Assessment, which is completed by our on-site team. This assessment is also used in any instances where we feel we need to investigate potential cases of modern slavery
- We realised that victims of modern slavery may feel “at risk” by speaking to one of our mangers or HR officials and therefore have implemented a Text “Aid” service to promote a communication method for victims that is discrete yet raises the alarm for us to act with the support of the GLAA. We currently have this function available at three of our largest sites.
- Nexus People form part of the quarterly GLAA committee meetings held for the midlands area where we share intelligence and best practice. Each representative share case studies with the view to work together to prevent such cases arising in the future. West Midlands Police share insight into their current operations for Nexus People and the rest of the committee to guide and provide intel where possible
- Where possible, we have held meetings with client key stakeholders to discuss modern slavery, our commitments and objectives and how we can support each other ’s goals and initiatives. Modern Slavery is always top of the agenda in any client discussions and relationships
- We have key GLAA investigator contacts who have provided us imperative guidance and foundation when we have found cases of exploitation this year. Our local GLAA contacts now hold a strong relationship with our HR and account management departments, in partnership to expose criminals and help victims
Key Areas of Improvement in 2021/22
- Building a strong relationship with Slave-Free Alliance (Hope for Justice) to protect our operations against exploitation, and improve our employee knowledge of modern slavery
- “Know your employees” expanding on day to day relationship building with temporary employees to improve welfare. Opening discussions that may highlight exploitation or mental health issues
- Annual refresher training with all permanent employees, providing case studies and lessons learnt including our action plan for 2021/22 contained in the annual Modern Slavery Statement
- Multi-Lingual briefings surrounding modern slavery to be conveyed quarterly across temporary workforce (mixture of all nationalities)
- Translation of policies and employee handbooks for temporary and permanent workforce
- We have a key focus on retaining our current workforce and are keen to work with our clients to improve attrition rates. Having a long standing settled workforce improves welfare and relationship building with our account management team.
Since the introduction of our anti-slavery polies and practices, we have worked with a GLAA Officer focusing on the Mansfield, Nottinghamshire area. Within our partnership throughout the year, we identified and provided evidence for 7 cases of Modern Slavery within the local area. On the back of our joint approach, there were 2 arrests made.
Once we suspect a Modern Slavery case, we follow this process:
- Modern Day Slavery Candidate Risk Assessment to be filled out by the Recruiter & Coordinator
- Full investigation carried out/observations/investigation
- A welfare meeting is held with the worker discretely
- Notify GLAA
Our management team, and key consultants have attended a Stronger Together full day workshop covering slavery and human trafficking, how best to prevent, report and highlight signs of exploitation.
Each new starter of the company is taken through training on exploitation and slavery, specifically on how to spot the signs and how to raise concerns within senior managers, including the complaints procedure and whistleblowing procedure.
The training conducted with all new starters, also includes a short video produced by the GLAA which shows real life examples of exploitation, which provides an understanding to our team on how exploitation takes place, and how we can support the GLAA with enquiries.
We run an annual email campaign each year, promoting the use of our Modern Slavery toolkit, whereby we also re-share our policy and the GLAA video, to re-iterate the importance and awareness.
Our company directors are the main drivers of all our internal policies and are therefore integral in driving the Anti-Slavery and Human Tracking policy. The directors ensure the training conducted by the HR and operational team is of excellent standard for our permanent and temporary employees.
The company have determined our temporary workforce are at the highest risk of modern slavery, in particular our European temporary employees. Our largest sites with high European workforces’ run a short induction presentation with all new starters during the interview and registration process. The induction covers all aspects of the role and our company policies and procedures, including Modern Slavery training and the GLAA video. Our employees are encouraged to report any signs of exploitation to their managers and are fully aware they have a central HR contact should they wish to raise concerns outside of the workplace. The training is provided to well over 2,000 new starters every year.
Nexus Workforce Limited