1. What is slavery?
1. The Modern Slavery Act (MSA) 2015 covers four activities:
Exercising powers of ownership over a person
The obligation to provide services is imposed by the use of coercion
Forced or compulsory labour
Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Arranging or facilitating the travel of another person with a view to their exploitation
2. This policy covers all four activities.
2. How is it relevant to us?
1. Modern slavery is a complex and multi-faceted crime, and tackling it
requires all of us to play a part.
2. At a very basic level, of course preventing exploitation and human
trafficking, and protecting our workforce and reputation makes good
3. The MSA 2015 recognises the important part businesses can and
should play in tackling slavery and encourages them to do more.
4. With this in mind, we need to pay particularly close attention to:
1. our clients and candidates;
2. our suppliers;
3. any outsourced activities, particularly to jurisdictions that may
not have adequate safeguards;
4. cleaning staff; and
5. corporate hospitality.
1. Everyone at Camino Partners, from our directors to our employees,
have responsibilities to ensure our fellow workers are safeguarded,
treated fairly and with dignity.
2. Everyone must observe this policy and be aware that turning a blind
eye is unacceptable and simply not an option.
3. We will:
1. maintain clear policies and procedures preventing exploitation
and human trafficking, and protecting our workforce and
2. be clear about our recruitment policy;3. check our suppliers:
4. check the clients and candidates we work with as part of our
business as a recruitment agency.
5. lead by example by making appropriate checks on all
employees, suppliers, clients and candidates to ensure we know
who we are working with;
6. ensure we have in place an open and transparent grievance
process for all employees;
7. seek to raise awareness so that our employees know what we
are doing to promote their welfare; and
8. make a clear statement in paragraph 5 below, that we take our
responsibilities to our employees, suppliers, clients and
1. listen and be approachable to employees;
2. respond appropriately if they are told something that might
indicate an employee is in an exploitative situation;
3. remain alert to indicators of slavery (see Identifying slavery);
4. raise the awareness of our employees, by discussing issues and
providing training, so that everyone can spot the signs of
trafficking and exploitation and know what to do; and
5. use their experience and professional judgement to gauge
We all have responsibilities under this policy. Whatever your role or
level of seniority, you must:
1. keep your eyes and ears open—if you suspect someone (a
colleague, a candidate or someone in our supply chain) is being
controlled or forced by someone else to work or provide
services, you must report it);
2. follow our reporting procedure set out in paragraph 7 below if a
colleague tells you something you think might indicate they are
or someone else is being exploited or ill-treated; and
3. tell us if you think there is more we can do to prevent people
from being exploited.
4. The risks
1. The principal areas of risk we face, related to slavery and human
1. Engaging employees; and,
2. Recruiting candidates for clients.
2. We manage these risk areas through our procedures set out in this
5. Our procedures
1. Anti-slavery statement1. We make a clear statement that we take our responsibilities to
our employees, people working within our supply chain, our
candidates, and our clients seriously.
2. We make this statement through this policy.
3. Our statement
We are a recruitment agency, and therefore at the heart of
employment relationships. We acknowledge our responsibility to
ensure, to the best of our abilities, that no candidate is subject to
slavery or trafficking.
2. Supply chains
1. We thoroughly check supply chains to ensure the potential for
slavery and human trafficking is significantly reduced.
2. We tell the companies we do business with that we are not
prepared to accept any form of exploitation.
3. We will do our best to ensure that all our supplier contracts
contain an anti-slavery clause.
4. We ensure we can account for each step of our supply
processes—we know who is providing goods and services to us
and we have mechanisms and processes in place to check.
1. Providing our recruitment agency services to clients
1. Our recruitment consultants are trained and monitored to
ensure that the potential for slavery and human trafficking
within the clients we deal with is significantly reduced.
2. To ensure the potential for slavery and human trafficking
is reduced as far as possible, we check our clients before
providing recruitment agency services. This includes:
1. conducting background checks on historic
2. investigating reputation
3. ensuring the candidates we provide have the
2. Internal recruitment
1. We always ensure all employees have a written contract
of employment and that they have not had to pay any
direct or indirect fees to obtain work.
2. We always ensure employees are legally able to work in
3. We check the names and addresses of our employees (a
number of people listing the same address may indicate
high shared occupancy, often a factor for those being
4. We provide information to all new employees on their
statutory rights including sick pay, holiday pay and any
other benefits they may be entitled to.
4. If, through our recruitment process, we suspect someone is being
exploited, the employee will follow our reporting procedures (See
6. Identifying slavery
1. There is no typical victim and some victims do not understand they
have been exploited and are entitled to help and support.
2. However, the following key signs could indicate that someone may be
a slavery or trafficking victim.
1. The person is not in possession of their own passport,
identification or travel documents.
2. The person is acting as though they are being instructed or
coached by someone else.
3. They allow others to speak for them when spoken to directly.
4. They are dropped off and collected from work.
5. The person is withdrawn or they appear frightened.
6. The person does not seem to be able to contact friends or family
7. The person has limited social interaction or contact with people
outside their immediate environment.
3. This list is not exhaustive.
4. Remember, a person may display a number of the trafficking indicators
set out above but they may not necessarily be a victim of slavery or
trafficking. Often you will build up a picture of the person’s
circumstances which may indicate something is not quite right.
5. If you have a suspicion, report it.
7. Reporting slavery
1. Talking to someone about your concerns may stop someone else from
being exploited or abused.
2. If you think that someone is in immediate danger, dial 999.
3. Otherwise, you should discuss your concerns with Natasha South,
Operations Director, who will decide a course of action and provide any
4. Not all victims may want to be helped and there may be instances
where reporting a suspected trafficking case puts the potential victim at
risk, so it is important that in the absence of an immediate danger, you
discuss your concerns first with a director before taking any further
We provide training to all of our staff members who are involved in managing
recruitment, clients, candidates, and our supply chains.
9. Monitoring our procedures
We will review our Anti-slavery policy regularly, at least annually. We will
provide information and/or training on any changes we make