Regulatory Law Advice for Recruitment Consultants

The Modern Slavery Act 2015 introduced changes in UK law focused on increasing transparency in supply chains. Recruitment agencies and consultants are at particular risk of being used to facilitate trafficking and exploitation.

We would recommend any business in the recruitment industry to prepare and publish a slavery and human trafficking statement. An enhanced due diligence processes should be adopted and a statement about the parts of the business and supply chains where there is a risk of modern slavery taking place (including the steps we have taken to assess and manage that risk)should be prepared.

The particular risks for a recruitment business include:

  • Employing an agent or employee who knowingly recruits trafficked or exploited individuals on behalf of a trafficking gang through your agency
  • Procuring candidates for a business who are actively exploiting vulnerable workers
  • Supplying exploited individuals to businesses for construction or factory work
  • Making arrangements for the travel of an exploited person or persons to a place of work
  • Supplying labour into the protected sector without obtaining authorisation from the Gangmasters and Labour Abuse Authority

It is essential that any recruitment business takes steps to avoid any of the risks above. Traffickers aim to be undetected and will exploit vulnerable persons and businesses. If your business is an easy target then you open up risks including:

  • An application for a slavery and trafficking risk order – this could put you out of business
  • Forfeiture or seizure of business propery
  • Criminal investigations
  • Prosecution
  • Prison

For friendly and confidential advice contact Ian Anderson on 0113 284 5062.