Modern Slavery and Human Trafficking Policy

Qube Recruitment Modern Slavery, Child Labour and Human Trafficking Policy

1. Policy Statement

Qube Recruitment has a zero-tolerance approach to modern slavery, child labour, and human trafficking. We are committed to acting ethically and with integrity in all business dealings and relationships, and to implementing effective systems and controls to ensure these practices do not occur within our business or supply chains.

2. Legal Framework

This policy complies with:

• Modern Slavery Act 2015 – prohibits slavery, servitude, forced or compulsory labour, and human trafficking in the UK.
• Human Rights Act 1998 – protects fundamental rights and freedoms.
• ILO Conventions – on forced labour and child labour.
• Gangmasters and Labour Abuse Authority (GLAA) standards – for labour providers.
• Home Office Section 54 Guidance – including the Employer Pays Principle (no worker should pay for a job). [stronger2gether.org]

3. Scope

This policy applies to:

• All Qube Recruitment employees, temporary workers, contractors, and consultants.
• All suppliers, clients, and business partners engaged by Qube Recruitment.
• All recruitment, onboarding, and supply chain activities.

4. Definitions

• Modern Slavery: Exploitation of individuals through coercion, deception, or control, depriving them of freedom.
• Human Trafficking: Arranging or facilitating the travel of another person for exploitation.
• Child Labour: Employment of individuals under the minimum legal working age or in hazardous conditions.

5. Our Commitments

• Due Diligence: Conduct rigorous checks on all candidates, including Right to Work, identity verification, and references.
• Supplier Compliance: Require all suppliers and clients to adhere to the Modern Slavery Act and Qube’s ethical standards.
• No Recruitment Fees: Prohibit charging recruitment fees to workers in line with the Employer Pays Principle.
• Training: Provide training to staff on identifying and preventing modern slavery and trafficking.
• Reporting & Whistleblowing: Maintain a confidential reporting mechanism for concerns related to exploitation.
• Audits & Monitoring: Regularly audit supply chains and recruitment practices to identify risks.

6. High-Risk Areas

We recognise that certain sectors (e.g., food processing, construction, logistics) are more vulnerable to exploitation. Qube Recruitment will monitor compliance through spot checks.

7. Responsibilities

• Directors & Managers: Ensure policy implementation and compliance.
• Employees: Report any suspicions of modern slavery or trafficking.
• Suppliers & Clients: Commit to ethical practices and allow audits when required.

8. Reporting & Remediation

• Suspected cases must be reported immediately to senior management.
• Qube Recruitment will investigate promptly and take corrective action, including notifying authorities and removing non-compliant suppliers.

9. Continuous Improvement

We will review this policy annually and update it in line with legislative changes and best practice guidance.