Aspire People Modern Slavery Policy and Statement
This statement is made as part of Aspire People’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).It summarises how Aspire People 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 August 2023 to August 2024. It was approved by the board of directors on 1st August 2023.
Daniel Dawkins
Managing Director
1. Our Business
Aspire People Limited is a limited company operating in the recruitment sector. We provide introduction services and supply temporary workers in the Education Sector. Aspire People is an independent business.
1.1 Who we work with
All the hirers that we work with, and all the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. We do not supply work-seekers to hiring companies through any unknown unaudited intermediaries. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.
All the hiring companies that we work with are in the United Kingdom. The workers we supply live in England.
Other relationships
As part of our business, we also work with the following organisations:
• HMRC
• The Recruitment and Employment Confederation
• APSCo
• The ICO
2. Our Policies
Aspire People has a modern slavery policy upon request or available on our website www.aspirepeople.co.uk. In addition, Aspire People has other policies which incorporate ethical standards for our staff and our suppliers.
2.1 Policy development and review
Aspire People’s policies are established by our directors and our senior leadership team, based on advice from HR professionals, industry best practice and legal advice, and in consultation with the REC. We review our policies on a regular basis, or as needed to adapt to changes.
3. Our Processes for Managing Risk
In order to assess the risk of modern slavery, we use the following processes with our suppliers:
• When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistleblowing.
• We conduct audits before entering 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 abide by our code of supplier conduct.
• 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.
4. Our Performance
As part of monitoring the performance of Aspire People, we track the following general key performance indicators:
• Face to face meeting with all workers/candidates and matched with worker/candidate ID badge.
• Regular spot checks on payslips.
• Digital IDVT incorporation – to verify original documents are not falsified and/or stolen.
• Automated alerts in our payroll software to alert any exceptions to NMW and unusually low hour to value rates.
Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of directors and our senior leadership team
• the percentage of suppliers who sign up to an appropriate code/ provide their own modern slavery statements.
• the percentage of workers and/or candidates supplied from audited businesses/ our preferred supplier list.
• the effectiveness of enforcement against suppliers who breach policies.
• the amount of time spent on audits, re-audits, spot checks, and related due diligence.
• the level of modern slavery training and awareness amongst our staff
We benchmark our indicators against industry best-practice/ discuss our indicators with suppliers/ carefully consider our indicators, to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.
5. Our Training
All our staff receive regular training and support that is appropriate to their role. In particular:
• Our leadership team and/or senior supply chain managers receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
• Our recruiters, HR personnel, and/or staff involved in our procurement and supply chains undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
• 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.