1: Introduction

1.1 Policy Overview
Redcone Recruitment Limited is committed to upholding the highest standards of ethical conduct and integrity in all its business operations. This Modern Slavery Policy outlines the company’s zero-tolerance stance on any form of modern slavery, human trafficking, forced labour, or exploitation. Redcone Recruitment Limited recognises its responsibility to combat modern slavery in all its forms and to ensure that its business operations, supply chains, and partnerships are free from practices that violate human rights.

As a provider of traffic management services and recruitment/supply of labour, the company understands that it operates in sectors that could be vulnerable to exploitation, and this policy has been implemented to ensure compliance with the Modern Slavery Act 2015 and international human rights standards.

1.2 Purpose of the Policy
The purpose of this policy is to:

• Ensure that Redcone Recruitment Limited has robust systems in place to prevent modern slavery, human trafficking, and exploitation in its operations and supply chains.
• Communicate the company’s commitment to ethical business practices, human rights, and transparency.
• Ensure that all employees, suppliers, contractors, and business partners are aware of their responsibilities in preventing modern slavery and are compliant with the Modern Slavery Act 2015.
• Foster a culture of openness, integrity, and accountability, encouraging employees and stakeholders to report concerns related to modern slavery.

1.3 Legal Framework
This policy is compliant with the following laws and standards:

• Modern Slavery Act 2015: Prohibits modern slavery, servitude, forced or compulsory labour, and human trafficking in the UK.
• Human Rights Act 1998: Protects fundamental human rights in the UK.
• ILO Conventions: International Labour Organization conventions on forced labour and child labour.
• UN Guiding Principles on Business and Human Rights: Establishes corporate responsibility for respecting human rights in business operations.

2: Scope

2.1 Applicability
This policy applies to all employees, contractors, suppliers, and third-party service providers engaged by Redcone Recruitment Limited, both in the UK and internationally. It covers all aspects of the company’s operations, including recruitment, procurement, and supply chain management. The policy applies to all sectors in which the company operates, including traffic management and recruitment/supply of labour services.

2.2 Definition of Modern Slavery
Modern slavery refers to the exploitation of individuals through practices that involve coercion, deception, or control, depriving them of their freedom. This includes:

• Forced Labour: Any work or service that individuals are forced to do against their will under the threat of punishment or harm.
• Human Trafficking: The recruitment, transportation, or transfer of individuals through the use of force, fraud, or coercion for the purpose of exploitation.
• Debt Bondage: When an individual’s labour is demanded as a means of repayment for a loan or debt, often with terms that make it impossible to repay the debt.
• Child Labour: The use of children in work that is harmful to their physical and mental development, or that deprives them of the opportunity to attend school.

3: Policy Details

3.1 Zero Tolerance for Modern Slavery
Redcone Recruitment Limited has a zero-tolerance approach to modern slavery and human trafficking. The company is committed to ensuring that:

• No one is subjected to modern slavery, forced labour, or human trafficking within the company or its supply chains.
• All employees, contractors, and business partners uphold the principles of this policy and comply with relevant human rights and labour laws.
• Any breaches of this policy will be addressed immediately and with appropriate action, including reporting to authorities and terminating relationships with offending parties.

3.2 Employee and Contractor Responsibilities
All employees, contractors, and associated personnel have a responsibility to prevent modern slavery in their operations and report any concerns. This includes:

• Awareness and Vigilance: Employees must remain vigilant to the risks of modern slavery and exploitation, especially when interacting with suppliers or recruitment agencies.
• Compliance with Labour Laws: Employees and contractors must comply with all applicable labour laws, including those related to minimum wage, working hours, and working conditions.
• Recruitment Practices: Employees responsible for recruitment must ensure that all workers are hired fairly and ethically, with no coercion, deception, or exploitation involved in the hiring process.

3.3 Supplier and Third-Party Due Diligence
Redcone Recruitment Limited recognises that its supply chains play a critical role in ensuring that modern slavery is not present in its operations. To this end, the company will:

• Conduct Risk Assessments: Regularly assess the risk of modern slavery in its supply chains, particularly in high-risk sectors or regions.
• Due Diligence: Perform thorough due diligence on all suppliers, contractors, and recruitment agencies to ensure compliance with anti-slavery policies. This includes reviewing their labour practices, conducting audits where necessary, and requiring them to sign and adhere to the company’s Supplier Code of Conduct.
• Contractual Obligations: Ensure that all contracts with suppliers, contractors, and third-party service providers include clauses requiring compliance with the Modern Slavery Act 2015 and other relevant human rights laws. Any breach of these clauses will result in termination of the business relationship.

3.4 Training and Awareness

3.4.1 Employee Training
Redcone Recruitment Limited will provide regular training to employees on modern slavery and human trafficking. This training will:

• Raise awareness of the risks of modern slavery and human trafficking in the company’s operations and supply chains.
• Provide guidance on how to identify the signs of modern slavery, such as poor working conditions, restricted movement, lack of control over wages, or suspicious recruitment practices.
• Offer clear reporting procedures for employees who suspect or encounter instances of modern slavery.

3.4.2 Management Training
Managers and senior leaders will receive additional training on their responsibilities to prevent modern slavery, with a focus on:

• How to conduct due diligence on suppliers and contractors.
• How to respond to modern slavery risks or allegations within their teams or operations.
• How to foster a culture of compliance and human rights within their departments.

4: Reporting and Whistleblowing

4.1 Reporting Modern Slavery Concerns
Redcone Recruitment Limited encourages all employees, contractors, and third parties to report any concerns or suspicions of modern slavery. This can be done via:

• Direct Reporting: Employees should report concerns to their line manager, the Human Resources (HR) department, or the company’s Modern Slavery Compliance Officer.
• Whistleblowing: Employees can also report concerns through the company’s confidential Whistleblowing Policy, which guarantees protection from retaliation for those who raise genuine concerns in good faith.

4.2 Investigation Process
Upon receiving a report of suspected modern slavery, the company will:

• Conduct an Immediate Investigation: The HR department, in coordination with the Modern Slavery Compliance Officer, will lead the investigation and gather all relevant information.
• Take Immediate Action: If any form of modern slavery is identified, the company will immediately act to protect the individuals affected, report the incident to the authorities, and take steps to prevent further occurrences.
• Support for Victims: Redcone Recruitment Limited is committed to supporting any employees or workers who may be victims of modern slavery by providing access to appropriate support services, such as counselling, legal advice, or assistance in finding alternative employment.

5: Monitoring and Compliance

5.1 Ongoing Monitoring
Redcone Recruitment Limited is committed to continuously monitoring and improving its systems to prevent modern slavery. The company will:

• Conduct Regular Audits: Regular audits will be carried out on high-risk suppliers and recruitment agencies to ensure compliance with this policy and ethical labour practices.
• Review Risk Assessments: Risk assessments of the company’s supply chains and operations will be reviewed regularly to identify new risks of modern slavery.
• Supplier Audits: Where necessary, Redcone Recruitment Limited will conduct supplier audits or site visits to assess working conditions and ensure compliance with the policy.

5.2 Annual Reporting
In accordance with the Modern Slavery Act 2015, Redcone Recruitment Limited will produce an annual Modern Slavery Statement, which will be publicly available on the company’s website. This statement will:

• Summarise the actions the company has taken during the financial year to prevent modern slavery in its operations and supply chains.
• Detail any modern slavery risks identified and the steps taken to mitigate those risks.
• Provide updates on the company’s progress toward its long-term goals of eliminating modern slavery in its business activities.

6: Responsibilities

6.1 Employee Responsibilities
All employees of Redcone Recruitment Limited are responsible for:

• Complying with this policy and adhering to all relevant laws regarding modern slavery.
• Reporting any concerns or suspicions of modern slavery, whether within the company or its supply chains.
• Participating in training on modern slavery and understanding the risks associated with their role.

6.2 Management Responsibilities
Managers and senior leaders are responsible for:

• Promoting a culture of compliance and ethical business practices within their teams.
• Ensuring that all team members are aware of this policy and their responsibilities regarding modern slavery.
• Conducting due diligence on suppliers and contractors to ensure compliance with anti-slavery laws.

6.3 Modern Slavery Compliance Officer
The Modern Slavery Compliance Officer is responsible for:

• Overseeing the implementation of this policy and ensuring that it remains effective.
• Leading investigations into reports of modern slavery and coordinating the company’s response to confirmed incidents.
• Liaising with external regulatory bodies, such as the Gangmasters and Labour Abuse Authority (GLAA), when necessary.

7: Consequences of Policy Violations

7.1 Employee Disciplinary Actions
Any employee found to be involved in modern slavery or the facilitation of modern slavery, or who fails to report known instances, will be subject to disciplinary action, which may include:

• Formal Warnings or retraining for minor violations.
• Termination of Employment for serious breaches.

7.2 Third-Party Actions
If a supplier, contractor, or third-party service provider is found to be involved in modern slavery or to have breached this policy, Redcone Recruitment Limited will take immediate action, which may include:

• Termination of contracts or business relationships.
• Reporting the offending party to relevant authorities.
• Refusing to engage in future business with the offending party.

8: Monitoring and Review

8.1 Policy Monitoring
Redcone Recruitment Limited will regularly monitor the effectiveness of this policy through audits, employee feedback, and risk assessments. Any weaknesses identified will be addressed immediately, and the company will continue to improve its procedures for preventing modern slavery.

8.2 Policy Review
This Modern Slavery Policy will be reviewed annually to ensure that it remains relevant and effective. Updates to the policy will be made in response to changes in legislation, business operations, or identified risks. Any revisions will be communicated to all employees and stakeholders.

9: Conclusion

Redcone Recruitment Limited is committed to maintaining a workplace and supply chain free from modern slavery, human trafficking, and exploitation. By adhering to this Modern Slavery Policy, the company ensures that all employees, contractors, and stakeholders understand their responsibilities in preventing modern slavery and upholding the highest ethical standards. Together, the company can contribute to a more just, fair, and sustainable world by eliminating modern slavery in all forms from its business operations.