Modern Slavery Statement

Workwell Global Modern Slavery Statement for Financial Year Ended 30/9/2023 Issued Pursuant to Section 54 of the Modern Slavery Act 2015

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Workwell Global has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Business, Structure, and Supply Chains

Workwell Global is the global brand and expert supplier of contractor management solutions to the world’s leading recruitment agencies. We assist Recruitment Agencies’ contractors in operating in compliance with all local tax and employment laws. We do this by utilising a network of professional partner companies (primarily accountants, lawyers, and tax advisers).

We employ people in the UK, EU, and the USA. We utilise outsourced, with regular training and inspection visits, services in India through QX Ltd. As we operate largely with white-collar, highly skilled, and relatively highly paid contractors (and the recruitment agencies that place them) we consider the risk level to be low.

Workwell Global offers solutions in more than seventy countries across Europe, the Middle East, and Africa as well as further afield.
We ensure that all our professional partner companies complete an annual ‘Statement of Conformity’ confirming that they are complying with all relevant legislation including data protection, anti-bribery, and modern slavery. We also issue them with our policy statement, as follows.

Anti-Slavery Policy

Workwell Global

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Workwell Global has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to dealing with our responsibility to eradicate modern slavery throughout our supply chains.

We expect the same high standards from all of our contractors, suppliers, and other business partners and will abide by our responsibility to ensure that those we deal with exercise prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for any Workwell Group company or on our behalf in any capacity, including employees at all levels, directors, contractors, suppliers, external consultants, third-party representatives, and business partners. Every individual employee has completed a training module regarding modern slavery.

Responsibility for the Policy

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

The CEO has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels is responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to James Harris at [email protected]

Compliance with the Policy

You must ensure that you read, understand, have been trained in, and comply with this policy.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your line manager or the CEO as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your line manager or the CEO or report it in accordance with our Whistleblowing Policy, summarised below, as soon as possible.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or the General Manager.

If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and partner organisations working on our behalf if they breach this policy.

The Workwell Group Board of Directors approved the above statement on 7th February 2024.

Kwasi Missah, COO