Modern Slavery Statement
This statement is made as part of Allen Speech & Language (ASL) Ltd’s (ASL Healthcare Professionals) commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how ASL 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 1st October 2020 to 30th September 2021. It was approved by the Director on 19th October 2021.
ASL is a limited company operating in the recruitment and Health sector. We provide temporary and permanent workers and introduction services in the healthcare sector. ASL is an independent business. The labour supplied to ASL in pursuance of its operations is carried out in the UK primarily London, Essex and Kent.
ASL considers that modern slavery encompasses:
– human trafficking
– forced work, through mental or physical threat
– being owned or controlled by an employer through mental or physical abuse of the threat of abuse
– being dehumanised, treated as a commodity or being bought or sold as property
– being physically constrained or to have restriction placed on freedom of movement.
ASL acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. ASL understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
ASL does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to ASL in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. ASL strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and in many cases exceeds those minimums in relation to its employees.
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 and permanent 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.
The hiring companies that we work with are located in the UK. The work-seekers and workers we supply live in the UK.
In general, ASL considers its exposure to slavery/human trafficking to be relatively limited. Nevertheless ASL has taken steps to ensure that such practices do not take place, in its business nor any organisation that supplies services to it.
ASL has a modern slavery policy available on request. In addition, ASL has the following policies which incorporate ethical standards for
our staff and our suppliers:
– Equal Opportunity and Diversity Policy
– Discrimination Policy
– Grievance Procedure
– Whistleblowing Policy
– Anti-Bribery and Corruption Policy
Policy Development and Review
ASL’s policies are established by our Directors and Senior Leadership Team, based on advice
from HR professionals, industry best practice and legal advice. We review our policies
annually, or as needed to adapt to changes.
Our Processes for Managing Risk
ASL carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
To our knowledge, ASL has not conducted any business with another organisation which has been found to have involved itself with modern slavery.
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
– When engaging with suppliers, as applicable, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
– We conduct audits before entering into a commercial relationship with any business where there is the potential for risk. These audited businesses form the basis of our preferred supplier list.
– We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
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 reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
– We require the businesses we work with to publish a modern slavery statement, as applicable.
– We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
– Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
– We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
Our staff are encouraged to bring any concerns they have to the attention of management.
As part of monitoring the performance of ASL, we track the following general key performance indicators:
– the level of modern slavery training and awareness amongst our staff
– the speed at which we investigate related compliance and the effectiveness of any whistle-blowing procedures
– the level of compliance and transparency in our supply chain
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by Directors and Senior Leadership Team:
– the percentage of suppliers who provide their own modern slavery statements
– the effectiveness of enforcement against suppliers who breach policies
We carefully consider our indicators and as applicable discuss our indicators with suppliers, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.
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. As part of this, our staff are encouraged to discuss any concerns that they
have. Training is refreshed regularly.