Since April 2016 all businesses with an annual turnover above £36m are obliged by the Modern Slavery Act 2015 (MSA) to publish Slavery and Human Trafficking statements (SHTs), setting out the steps that they have taken to combat modern slavery within their businesses and supply chains (including the recruitment agencies they use).
However, as Ravi Murphy, director of leading recruitment compliance and employment law firm Lawspeed explains, “Just because a recruitment agency has a turnover below the threshold they shouldn’t be lulled into thinking that the issue of modern slavery has no relevance for their business.”
Murphy continues, “The Modern Slavery (Transparency in Supply Chains) Bill passed its second reading in Parliament on 24th March 2017. As result, it will force public sector organisations to exclude businesses, including recruitment agencies, without a published SHT from their supply chains.
Recruitment agencies without a SHT supplying workers to public sector hirers are likely to find themselves excluded from tender processes, have their assignments terminated, and their contracts being awarded to better-prepared competitors.”
So does this mean that that an agency supplying workers only within the private sector are off the hook? “No, they shouldn’t be complacent” says Murphy. “If they supply staff to a private sector hirer who in turn supplies goods or services to any public sector hirer, they will be expected to show that their recruitment agency has a SHT.”
Murphy concludes, “To help recruitment agencies prepare for the changes, we have looked at the proposed legislation and developed a suite of recruitment specific guidance, including checklists for registering candidates, MSA training and audits, through to Anti-Slavery and Anti-Human Trafficking policies and SHTs tailored to the recruitment sector.”
Recruitment agencies seeking information on Modern Slavery Compliance should visit https://www.lawspeed.com/modern-slavery-compliance/, or alternatively they can call Lawspeed on 01273 236236 or email [email protected]
Adrian, a highly experienced lawyer, founded Lawspeed in 1997. He is responsible for developing our extensive portfolio of products and services, including the widely used Lawspeed contract templates. Adrian is an expert on “recruitment law” and specialises in contracts, regulatory compliance, employment status and dispute handling. He is chair of the trade body the Association of Recruitment Consultancies, the only lawyer lead recruitment trade body in the UK. Adrian and his co-director Ravi devised Standards in Recruitment as a vehicle for helping drive up standards and compliance in the industry.
Adrian is our lead in discussions with the government over regulatory evolution. Apart from assisting with client support, Adrian’s primary role is research and development into methods of business delivery, our latest service Proterms being his most recent project. Adrian heads our IR35 lawyers team.