Introduction
Instajobs has published this statement in compliance with section 54 of the Modern Slavery Act 2015 (“the Act”). We are fully supportive of all measures taken by the UK government to eradicate slavery and human trafficking.
We are focussed on the UK market and view our overall risk to be low. However, we are not complacent and have a zero-tolerance policy approach to any form of modern slavery, forced labour, human trafficking, or rights violations. We are committed to acting ethically and with integrity and transparency in all business dealings.
As required by the Modern Slavery Act 2015 (the “Act”), this statement describes the steps which Instajobs takes to ensure that slavery and human trafficking is not taking place in any part of our business or in any of our supply chains.
Organisational structure
Instajobs Limited has business operations in the United Kingdom. We operate in the Public Sector, Retail, Construction and Civil Engineering sector. For more information about the Company, please visit our website: www.instajobsuk.com.
Policies
We operate a number of internal policies to ensure that we conduct business in an ethical and transparent manner.
These include the following:
• Recruitment and selection policy - We conduct checks on all prospective employees to verify that they are eligible to work in the UK. Certain roles require a Disclosure and Barring Service (Enhanced DBS) check where employees may be working with vulnerable people.
• Supplier code of conduct - We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.
• Whistleblowing policy - We operate this policy so that employees are able to raise concerns about how staff are being treated or practice within our business or our supply chains without fear of reprisal.
• Staff code of conduct - We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
• Procurement policy - We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and checks undertaken to help verify this.
• Safeguarding policy - This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns. We make sure our suppliers are aware of our policies and adhere to the same standards.
Due Diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:
• Internal supplier audits.
• External supplier audits.
• Checking certain suppliers with external third parties for any slavery or human trafficking risks.
Our due diligence procedures aim to:
• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
• Provide protection for whistleblowers.
Risk and compliance
The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:
• Evaluating the slavery and human trafficking risks of each new supplier.
• Creating an annual risk profile for key suppliers.
• Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.
We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries.
We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
Effectiveness
The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:
• We will contact suppliers to enquire about their modern slavery practices every 12 months.
• We will train our staff about modern slavery issues and increase awareness within the Company.
• We will carry out a regular audit of suppliers - 100% of suppliers each year.
Training our staff
The business requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company's training covers:
• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
• What external help is available.
• What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chain.
All new employees are educated on the Act, and they are made aware of the important role that they play in identifying signs of breaches of the Act within our employee base and within our suppliers. Employees are actively encouraged to report their concerns either internally or via our whistleblowing policy.
Our aim is to raise awareness of the issues and increase informed scrutiny. We are committed to ensuring awareness of the Act across the business as part of our efforts to help eliminate all forms of compulsory labour and human trafficking.
Instajobs Commitments
• Instajobs strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain.
• The company expects that all its customers and suppliers will hold their own supply chain to the same high standard surrounding the issues of modern slavery.
• Instajobs expects every employee to support and uphold the commitment to engage with stakeholders and suppliers to address the risks of modern slavery where this could be a concern.
• Instajobs Limited has implemented policies to ensure that, in all areas of the business and within our supply chain, we act ethically and with integrity and transparency.
• We are committed to the training and development of all staff to understand the meaning of slavery and human trafficking so that they are alert to identify possible abuse within Instajobs and externally.
