MPI Limited and its parent company MPI (Herts) Limited (MPI) remain committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses and this statement sets out the steps that MPI has taken and is continuing to take, to uphold its zero-tolerance approach to any form of modern slavery.
MPI provides suitably qualified and experienced temporary labour and permanent staff to industry and it is committed to ensuring that its staff and the 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.
All staff within MPI are expected to comply with all laws, act in accordance with MPI’s Modern Slavery Policy, with integrity, honesty and respect for the human rights of others.
Modern slavery forms part of the onboarding training package undertaken by new employees are required to sign a statement that they have read and understood the Modern Slavery policy and Anti-Fraud, Bribery, Money Laundering and Corruption Policy.
Training and information on modern slavery is provided to members of staff annually and recorded. In 2023, 100% of employees received awareness-raising information that reiterated what modern slavery is, the signs to look out for within the business and industries we provide labour to, the checks that need to be undertaken and how to report suspected modern slavery activities and all acknowledged that they had read and understood the briefings.
All MPI employees have access to dedicated channels through which they may voice concerns through local and central reporting mechanisms. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to their line manager, to the Quality and Sustainability Director or contact the Modern Slavery Helpline or Police. To date there have been no reports made surrounding these issues, however the senior leadership team are committed to ensuring that any investigations shall be prompt and effective, should actual or suspected modern slavery activities be reported. MPI is committed to protecting employees when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially, professionally and without fear of retaliation.
We monitor our risks by looking at:
· The number of suppliers who provide their own modern slavery statements,
· The effectiveness of enforcement against any suppliers who breach policies,
· The amount of time spent on audits and related due diligence, and
· The level of modern slavery awareness amongst our staff.
As part of our initiative to identify and mitigate risk, the following potential risk areas have been identified:
1. Provision of temporary workers to clients
Risk: Temporary workers placed with clients may be enslaved or human trafficked individuals.
Risk control:
Modern day slavery checks are interwoven throughout MPI’s end-to-end recruitment business practices. At the outset of the recruitment process, our recruitment team ensure strict compliance checks are carried for all candidates.
Eligibility to work in the UK checks are carried out for all assignees and our recruiters and administrators verify the identity of each worker before supply commences. Copies of forms of identity such as passports are taken and the originals are not retained by MPI, only the copies are in electronic stored documents on our candidate database.
Audits are carried out throughout the year of entries on the database to identify errors, anomalies and inconsistencies in candidate and assignee records.
Employment agencies are prohibited by law, from charging or seeking to charge work-seekers to find or seek work for them and MPI complies with this. Individuals are not subject to hidden payments of any form.
All employees and assigned contract workers are treated fairly and a contract for or of services is entered into at will by both parties.
Payments are agreed before the assignment commences. Wages are not unfairly held and made weekly a week in arrears to the assigned worker’s personal or business bank account and monthly for employees.
A flag up system highlights requests made for monies to be paid into a different account, enabling checks to be carried to eliminate the risk of bonded labour having no access to their earnings.
All payment mechanisms comply with HMRC legislation in relation to tax, National Insurance and pension contributions.
Our employees have been made aware to look out for signs of modern slavery within the teams of assigned workers when undertaking onsite visits and safety tours.
2. Suppliers that make up MPI’s supply chain
Risk: Having suppliers that contravene the Modern Slavery Act 2015.
Risk control:
As part of our commitment to identify and eradicate slavery and human trafficking, we also have in place a process to undertake due diligence on our supply chain network including second tier recruitment agencies where utilised, to ensure compliance with legislative obligations. All suppliers are required to complete and return a supplier appraisal questionnaire that summarises their adherence to the Modern Slavery Act 2015. If our due diligence reveals any issues, we are committed to taking appropriate action, including but not limited to:
· Working with the appropriate organisations to improve standards,
· Removing that organisation from our preferred supplier list,
· Passing details to appropriate law enforcement bodies.
Our effectiveness in combating slavery and human trafficking
MPI has not received any reports of instances of modern slavery over the past financial year.
Further steps
· MPI will continue to raise awareness of modern slavery and of the need for proper due diligence to be applied throughout the coming year and formally re-brief all employees by the end of July 2024.
· Modern slavery will continue to be included within the induction process for all new employees.
· MPI shall continue to conduct regular audits of its assignees, candidate registration and vacancy fulfilment processes to ensure that only eligible workers are assigned to clients.
· MPI will assess new suppliers to ensure that they adhere to the Modern Slavery Act 2015.
· MPI shall continue to monitor and investigate any reports of modern slavery or human trafficking.
Issue: 9 Approved by: E. Pearson Chairperson
Reviewed: 07 July 2024 Edward Pearson