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Modern Slavery

Modern Slavery Statement

This statement is made as part of Hewett Recruitment’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how Hewett Recruitment 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 April 2019 to March 2020.  It was approved by the board of directors on 18 April 2019.

1. Our Business

Hewett Recruitment is a limited company operating in the recruitment sector.  We provide introduction services and the supply temporary workers in Industrial, Engineering, IT & Technical, Financial and Commercial sectors.

Hewett Recruitment is an independent business. 

1.1. Who we work with

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

1.2. Other relationships

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


2. Our Policies

Hewett Recruitment has a modern slavery policy. In addition, Hewett Recruitment has the following policies which incorporate ethical standards for our staff.

  • Equality & Diversity Policy
  • Customer Service & Complaints Policy
  • Whistle Blowing Policy
  • Anti-Corruption & Bribery Policy
  • REC Code of Ethics


2.1 Policy development and review

Hewett Recruitment’s policies are established by our leadership team, based on advice from HR professionals, industry best practice and legal advice, and in consultation with any relevant governing or regulatory body.  We review our policies annually, or as needed to adapt to changes. 


3. Our Processes for Managing Risk

Hewett Recruitment recognise the importance of all staff having awareness of the severity of modern slavery and as such have introduced the following processes and checks into its day to day recruitment of temporary workers:

  • Red Flag Checklist
  • Modern Slavery Worker Questionnaire – to be incorporated into the standard interview process
  • Monthly Audits – of temp data to highlight multiple occupancy, same contact details for multiple workers

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

  • We review the potential for risk at regular intervals including the possibility of re-auditing a supplier or conducting spot checks.
    • Reviewing our supplier list
    • Identifying potential risks based on nature of business and sector

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 collaborate with our suppliers in order to improve standards and transparency across our supply chain by asking suppliers if they have their own Modern Slavery Policy/Statement
  • Our staff are encouraged to bring any concerns they have to the attention of management.


4. Our Performance

As part of monitoring the performance of Hewett Recruitment, we track the following general key performance indicators: 

  • the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements

We 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.


5. Our Training

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

  • All of our staff receive informal awareness as part of their initial staff induction information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
  • The ‘Red Flag list is discussed and the Modern Slavery Policy is explained in depth.
  • As part of this, our staff are encouraged to discuss any concerns that they have.  Training is refreshed when required and forms part of the formal employee induction programme.

As part of Hewett’s continued training – formal Modern Slavery Awareness training will be scheduled during 2020 through the REC


Modern Slavery Policy

  1. Hewett Recruitment is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses. 
  2. Hewett Recruitment is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses. 
  3.  Hewett Recruitment provides appropriate training and awareness information for all of its staff. 
    In particular:
  • All of 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.
  1. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to a director of the business and have identified the need to create an Escalation Process which will be launched in the first quarter of 2020.
  2. Reports surrounding these issues are taken extremely seriously by our board of directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
    • Working with the appropriate organisations to improve standards including;
      1. Stronger Together
      2. Hope for Justice
      3. Recruitment & Employment Confederation
    • Removing that organisation from our preferred supplier list,
    • Passing details to appropriate law enforcement bodies.
  3. We will regularly monitor our risks in this area at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.  Replacing periodic checks, monthly checks of temporary workers data will be taking place from January 2020 and will include:
    •  Addresses – checking for multiple occupancy of either one residence or black of flats, close proximity
    • Contact numbers: checking for same contact numbers of sequential numbers leading in to  potential control of workers by and individual issuing multiple phones
    • Next of Kin: checking for potential non-related names individuals or same contact for multiple individuals
    • Email addresses: checking for any duplication of email address suggesting control by one person or group of persons
    • Bank details:  checking if bank account is in own name, no duplicate bank account numbers etc
    • Change of bank details: ensuring nay subsequent request or change of bank details also match the individual personally


As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

  1. We would also recommend reading this in conjunction with our other policies, including our:
    • Anti-bribery / corruption policy, and
    • Whistle-blowing policy.


This policy was adopted in April 2017 after being agreed by our board of directors.  It is reviewed annually to ensure it continues to support the organisations commitment to eliminating Modern Slavery