Modern Day Slavery & Human Trafficking

360 Connections Group Ltd

This statement is made as part of 360 Connections Group Ltd commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how 360 Connections Group Ltd operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff. 

This statement is published in accordance with section 54 of the Act and relates to the financial year Apr 2023 to Mar 2024. It was approved by board of directors on 03.03.2023.

Mohammed Noorani

HR & Operations Director

 

  1. Our Business

360 Connections Group Ltd is a limited company specialising in the Driving, Industrial and Nursing recruitment sectors.  We supply temporary workers.

360 Connections Group Ltd is an independent business. 

 

  1. Who we work with:

All the hirers that we work with, and all the work-seekers we provide, are known to and identified by our staff.  All the temporary workers we supply are identified by our staff. Some of these work-seekers operate through umbrella companies.  Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company. 

The hiring companies that we work with are based across England. The work-seekers / workers we supply live across England.

 

  1. Other relationships

As part of our business, we also work with the following organisations:

 

360 Connections Group Ltd has a modern slavery policy.

In addition, 360 Connections Group Ltd has the following policies which incorporate ethical standards for our staff and our suppliers.

 

  • Anti-Bribery Policy
  • Whistleblowing Policy
    • Policy development and review

360 Connections Group Ltd policies are established by our directors / our partners / our senior leadership team / briefly identify the decision makers, based on advice from HR professionals, industry best practice and legal advice, and in consultation with REC (The Recruitment & Employment Confederation).  We review our policies annually to adapt to changes which may arise. 

 

  • Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

 

  • When engaging with suppliers, we may ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistleblowing.
  • We may conduct audits before entering a commercial relationship with any business where there is the potential for risk.  These audited businesses form the basis of our preferred supplier list.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain.  However, we continue to be alert to the potential for problems. 

Additionally, we have taken the following steps to minimise the possibility of any problems:

 

  • We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
  • We require the businesses we work with to address modern slavery concerns in their policies / publish a modern slavery statement.
  • We collaborate with our suppliers in order to improve standards and transparency across our supply chain.

Our staff are encouraged to bring any concerns they have to the attention of management.

 

  • Our Performance

As part of monitoring the performance of 360 Connections Group Ltd, we track the following general key indicators: 

 

  • Multiple work-seekers registering at a single address.
  • Multiple work-seekers wishing to use bank details other than their own.
  • Patterns with work=seekers being introduced/escorted to register.

Based on the potential risks we have identified, we have also established the following key indicators, which are regularly assessed by our board of directors / the partners / our senior leadership team

 

  • the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
  • the percentage of workers and/or candidates supplied from audited businesses / our preferred supplier list
  • the effectiveness of enforcement against suppliers who breach policies
  • the amount of time spent on audits, re-audits, spot checks, and related due diligence
  • the level of modern slavery training and awareness amongst our staff

We benchmark our indicators against industry best-practice / discuss our indicators with suppliers / carefully consider our indicators, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

 

  • Our Training

All our staff receive training and support that is appropriate to their role.  In particular:

 

  • All our staff 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.

As part of this, our staff are encouraged to discuss any concerns that they have.