Modern Slavery & Human Trafficking Statement
This policy ensures that Hoggett Bowers complies with section 54 of the Modern Slavery Act 2015, and sets out the responsibilities for employers and employees.
Hoggett Bowers is committed to ensuring that all of its business operations are free from involvement with slavery or human trafficking.
Hoggett Bowers is an executive search organisation. We help clients with a broad range of senior executive search, interim management and non-executive appointments.
Our key markets are:
• Financial Services
• Technology, Media & Communications
• Not for Profit & Public Sector
Hoggett Bowers also expects the same high standards from all of its suppliers, contractors and other business partners, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Hoggett Bowers accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
The organisation has policies in place that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations.
• All members of staff have a responsibility to prevent, detect and report any instances of slavery and trafficking. Anyone who has concerns regarding acts or potential acts of slavery and trafficking should speak to their line manager in the first instance. If for any reason a person is not able to speak to his or her line manager, he or she should contact the HR department.
• The organisation's code of conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Hoggett Bowers and its subsidiary companies are required to comply with all the laws and regulations of the countries in which they operate.
• Hoggett Bowers complies with discrimination legislation concerning colour, gender, sexual orientation, marital status, race, religion or religious belief, nationality, disability or ethnic or national origin, religious belief, age, disability.
• Hoggett Bowers does not condone any form of corrupt or unethical behaviour in business dealings. Employees are prohibited from offering or accepting any bribes, gifts or facilitation payments.
• All employees are treated with dignity and respect. Any harassment or bullying is unacceptable.
• All our employees are paid at least the National Minimum Wage / National Living Wage and have the right to work in the UK.
• Hoggett Bowers ensures strict compliance checks are carried for all candidates it supplies to verify their right to work.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers.
Responsibility for the policy
The Executive Chair has overall responsibility for ensuring that this policy complies with the Company’s legal and ethical obligations.
The Group Finance Director has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company’s business or supply chains.
Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
Training and communication
Hoggett Bowers provides training for all employees who are involved in the supply chain on issues relating to slavery and human trafficking.
The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Hoggett Bowers slavery and human trafficking statement for the financial year ending 31 December 2017.
31 December 2017