BONHILL PARTNERS

VOLUNTARY MODERN SLAVERY STATEMENT

We oppose slavery and human trafficking in all its forms. We are committed to improving our practices to combat modern slavery in our business by taking steps as far as we are able to ensure that our supply chains are free from slavery and human trafficking. This policy sets out the steps we have taken or intend to take to understand potential modern slavery risks within our business structure and supply chains as well as the steps we have taken or intend to take to eliminate those risks.

About us

We are Bonhill Partners Ltd, a company registered in England and Wales with company number 14359154 (we, us, or our). We operate in the managed service and recruitment industries and provide managed service solutions as well as recruitment services specialising in the IT sector for temporary projects within our clients’ businesses.

Our annual turnover is under £36 million. So although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015 (Act), we are making this voluntary statement to show our commitment to ethical trading principles and to identify risks and tackle modern slavery and human trafficking within our business and in our supply chains.

This policy applies to all our staff, agents, and suppliers within the United Kingdom and, if applicable, overseas.

Modern slavery

Modern slavery includes any conduct that constitutes modern slavery under the Act and includes child labour, human trafficking, forced or compulsory labour, debt bondage, deceptive recruitment for labour and services, slavery and slavery-like practices, servitude, and other forms of serious exploitation.

Indicators of modern slavery may include:

  • Excessive working hours;
  • Isolation;
  • Abusive working conditions; and
  • Underpayment, no payment, or withholding of payment of wages.

Our commitment to combatting modern slavery

In our supply chain, we are involved in the provision of managed services and recruitment services within the United Kingdom. As such, we are committed to ensuring that:

  • Our clients who we recruit for are contractually obliged to ensure that they do not engage in modern slavery for any candidate we place in their business;
  • The personnel we place in businesses on a temporary worker basis do not experience any indicators of modern slavery; and
  • Any temporary workers we place are paid fairly and in accordance with National Minimum Wage, have a written contract of employment, and are legally entitled to work in the United Kingdom.

We have implemented or intend to implement the following measures to identify, reduce, and combat the risks of modern slavery in our operations and supply chains:

  • Investigating allegations of modern slavery in our business operations and supply chains;
  • Engaging with our suppliers (including any umbrella companies that we use to employ any temporary worker) to improve our position in preventing and readily identifying, reducing, and combatting modern slavery risks in relation to our supply chains;
  • Training our staff on their obligations under this policy; and
  • Implementing processes to mitigate modern slavery risks that we consider necessary and reviewing such processes from time to time.

We also have the following policies in place relevant to modern slavery which we continuously review and update:

  • Whistle-blowing Policy;
  • Anti-Slavery and Human Trafficking Policy;
  • Employee Handbook;
  • Equal Opportunities Policy;

Due diligence

We expect those we do business with to address modern slavery within their own business operations and supply chains to the same standard. We vet suppliers and sub-contractors to ensure they are committed to ethical labour practices. Accordingly, before entering into or during the term of an agreement with any third party for services or supply arrangements, we may endeavour to obtain from that supplier certain assurances of compliance with the Act and/or this policy and the prevention of modern slavery within their supply chains. We may also investigate any modern slavery concerns identified in relation to our suppliers who are then expected to cooperate and, where relevant, procure their suppliers, contractors, agents, and related entities to cooperate with our investigations and any further measures we consider are appropriate to mitigate the identified modern slavery concerns.

Effectiveness in combatting slavery and human trafficking

We use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • The percentage of suppliers and sub-contractors vetted for ethical labour practices;
  • The number of inspections of direct suppliers and sub-contractors in our supply chains in the past year;
  • The number of reported breaches in the past year;
  • The percentage of staff receiving training on identifying and addressing the risk of slavery and human trafficking in our business and supply chains.

Training

All staff have a role to play in preventing, detecting, and reporting modern slavery risks. Our staff are required to immediately notify management of any actual or suspected modern slavery which may be in breach of this policy.

We encourage this through our regular meetings with relevant personnel. We may also conduct anonymous surveys for our staff to report back to us on various parts of our business.

Our staff must immediately notify management if they engage with a supplier who engages in or is suspected to engage in modern slavery or fails to take measures to prevent modern slavery risks in their supply chains. We may further investigate the supplier’s supply chains and assess whether its operations are consistent with any contracts we may have in place with the supplier.

Variations to this policy

We may vary, remove, or replace this policy at any time.

Implementation

This voluntary slavery and human trafficking statement is made for the financial year ending 30 September 2023. It was approved by the board on 17/10/22.

Samuel Perrin
Director Co-Founder
Bonhill Partners Ltd
Date: 17/10/22