Modern Slavery

This statement sets out Spencer Clarke Group’s (SCG) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during 2025-2026 financial year.

As part of our multi divisional approach operating throughout various sectors, we recognise our responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.

SCG is totally committed to preventing slavery and human trafficking in its corporate activities; furthermore, to ensuring that its supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chains

This statement covers the activities of SCG:

Operating since 2017 as an Employment Business, Employment Agency, and we recruit into a large number of sectors throughout the UK; including but not limited to; Accountancy & Finance, Education & SEND, Construction, Trades & Labour, Healthcare, Social Care & Nursing , Corporate Function & Business Support, IT & Digital, Property & Asset Management, Planning, Development & Regeneration, Highways, infrastructure & Engineering, HR & Workforce Development and Housing.

As part of our continuing commitment to the highest standards, we have the below accreditation within regulatory bodies:

• Recruitment & Employment Confederation (REC) regular audit ensuring regulatory standards are maintained.
• The Association of Professional Staffing Companies (APSCO) – APSCO+ accredited
• ISO 9001:2015

Our suppliers provide services to us such as IT and Digital Services, Payroll Services, Office Equipment and supplies and Office Maintenance. The majority of our suppliers are UK and we currently operate from one location/office.

Managing Risk

Appropriate Modern Slavery Policies are in place coupled with due diligence and risk assessments with relevant follow-up processes. Risk assessment include; engagement with experts, supply chain mapping, research and supplier surveys, engagement and discussion.

Transparency and openness is encouraged throughout all business operations including supply chain along with the deliver of appropriate training to ensure awareness and knowledge. Continuous reviews are in place to manage and improve policies, this ensure they are relevant and fit for purpose; then, agreed and signed by the a Director.

To ensure suppliers have appropriate policies and procedures we undertake pre-supply engagement and audits; inclusive of Modern Slavery, Human trafficking, forced labour, human rights and whistle-blowing checks.

Once audits are complete the supplier must agree to the terms of our supplier code of conduct before they can be added to any preferred supplier list; the list is then audited annually or if concerns are raised.

High risk areas have been identified within our supply:

• Women
• Refugees
• Migrants
• Temporary Work
• Seasonal Work
• Construction Industry

These risks are mitigated where possible through rigorous compliancy checks to ensure the identification of persons and their right to work in the UK.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

• Policies - Must be signed by a Director; reviewed and updated as required annually or in line with legislative changes.
• Risk assessments - Conducted internally with oversite and sign-off by a Director.
• Investigations/due diligence - Conducted internally with oversite and sign-off by a Director.
• Training - Implemented for all new starters and reviewed/topped-up annually to maintain awareness for signs of Modern Slavery in line with key indicators inclusive of reporting procedure escalating any concerns to senior management.

Related Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing Policy – ensures simplicity for candidates, clients, suppliers and other business partners a like to disclose any concerns including any around Modern Slavery and/or supply chain, without fear of retaliation
• Employee Code of Conduct – clearly outlines to employees the actions and behaviour expected of them when representing SCG as we continue to maintain the highest standards of conduct and ethical behaviour when operating and managing its supply chain.
• Supplier Code of Conduct - proactive outline of steps to ensure that slavery and human trafficking is not present in operations or supply chains through the provision of evidence of sustainability processes and policies.

Due Diligence

We undertake due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier
• requirement for all suppliers to agree to the supplier code of conduct
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through our Finance team, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• taking steps to improve substandard suppliers' practices, including providing advice to suppliers through our Finance team, and requiring them to implement action plans
• using lists of suppliers approved by appropriate governing bodies, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
• employing rigorous compliancy checks to ensure the identification of persons and their right to work in the UK. We are also a Living Wage employer.
• we respect the right of employees to form and be members of trade unions and will work together with trade unions to illicit harmonious relationships.

A suspected case of modern slavery may be reported by any employee or indeed customer and suppliers. This report will be dealt with in line with the reporting procedures in the modern slavery policy.

Performance Indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

• requiring all staff to have renewed training on modern slavery by 31/03/2025;
• require all new suppliers to agree to our supplier code of conduct and work towards having 100% of our existing suppliers agree in the next 12 months.
• achieve a 100% supplier payment punctuality for the next financial year
• continue to develop a robust process for due diligence checks whereby we evaluate potential suppliers before they enter the supply chain by 31/03/2024; and
• reviewing its existing supply chains whereby we evaluate all existing suppliers by 31/03/2025.

Training

We require all staff within our organisation to complete training on modern slavery as a module within our wider human rights/ethics/ethical trade training programme.

We require all staff to complete or renew an online training course by 31/03/2025.

Our modern slavery training covers:

• our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Awareness Raising

Initiatives below are engaged to ensure SCG are raising awareness of Modern Slavery where possible:

• Modern Slavery Statement published on our website
• Regular staff training includes; basic principles of the Modern Slavery Act 2015, how to identify and prevent slavery and human trafficking, how to flag and report issues and finally directing them to external help (Modern Slavery Helpline)

This statement has been created using the Modern Slavery Assessment Tool (GOV.uk) and is reviewed/updated annually.