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Slavery and Human Trafficking Statement

 Slavery and human trafficking statement made on behalf of all companies within the red group further to the provisions of the UK modern slavery act 2015 

Statement by the chief executive of the red group

We are proud of the conditions of employment for all our employees throughout the red group. Given the nature of our business, our board and management teams each consider that there is minimal risk that, either the red group or its limited supply chains which support our business activities, are in any way involved in, supportive of, or complicit in slavery and human trafficking. The employment and procurement practices operated by the red group ensure that the companies within our group are rightly viewed as law-abiding and supportive employers. To the extent that our group companies operate as a purchaser of goods or services we expect a high level of ethical conduct from those businesses with which we do business within our limited supply chain.

Organisation's structure

Red group, which includes its main trading entity red commerce limited, is primarily a staffing and it consulting business that sources and supplies the services of skilled it professionals (“consultants) to provide services to its customers on a permanent or contractual basis. These consultants are either engaged directly by red or through a business to business arrangement. The ultimate parent company, red topco limited, and the main trading subsidiary red commerce limited, are incorporated in the united kingdom and headquartered in london. The group also operates out of offices in germany, usa and brazil, and has approximately 220 employees worldwide. The red group operates largely in these jurisdictions but also conducts business in a wider number of countries around the world.

Our supply chains

The red group’s supply chains are limited. In the provision of staffing and recruitment solutions, we engage technically skilled professionals in the it sector as well as general professional services organisations. We do use routine services for the maintenance and support of our office operations such as cleaning and technical support services for such things as it, telephones and communications infrastructure.

We do not act as a producer, manufacturer or retailer of physical goods and have no supply chain in relation to such activities.

Anti-slavery policy statement:

“the red group has zero tolerance to slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.”

This anti-slavery policy statement is the principal articulation of the red group’s policy on slavery and human trafficking. It is intended to inform and influence all the operational procedures within the red group.

Our stated anti-slavery policy statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure (amongst our other priorities) that slavery and human trafficking is not taking place anywhere in our business or related supply chains.

Due diligence and implementation processes for slavery and human trafficking

The red group works primarily in industries and with consultants that would not ordinarily be considered to be at risk of the perils of modern slavery and human trafficking. Notwithstanding, we take our obligations and responsibilities seriously and as part of our initiative to identify and mitigate risk (including in relation to that of slavery and human trafficking) we operate a range of policies and procedures appropriate to the companies within the red group.  These include the following:

Pay & remuneration:

Red works closely with all of its customers to ensure that market rates are paid in respect of the services provided by the supplier and its personnel. Red is in compliance with all minimum wage acts and does not supply workers to clients on zero-hour contracts.

Recruitment policies:

Our recruitment takes place through a combination of direct applications, referrals, targeted headhunting activities and through utilising our extensive global network of candidates. All employees who join the red group and consultants that we provide to clients are subject to checks to ensure they are genuine applicants, operating as free agents and with the appropriate qualifications.

Our internal recruitment team and recruitment consultants are trained to follow best recruitment practice to establish the identity, work history, qualifications and availability of the expert to provide the services. Every consultant that we assign is required to provide evidence of their identification, right to work (if relevant) and references which are verified by our employees prior to the work commencing. Checks are also undertaken to verify the nature of the relationship between the consultant and the entity with whom we are contracting when such arrangements are on a business to business basis.

Whistleblowing

Red encourages all its workers, customers and other business partners to report any concerns related to its direct activities or supply chains. Such concerns are investigated by our dedicated legal & compliance department and any irregularities are reported to the ceo and the board. Red operates a strict no retaliation policy against any employee who makes such a disclosure.

On-boarding policies

Compliance checks: when on-boarding new consultants and other third party suppliers, red obtains documentation to assist us in carrying out reasonable compliance checks. Contractual assurances regarding ongoing compliance with our requirements and compliance with employment practices are routinely sought.

Red monitors all placements at all stages in the recruitment process where identification and compliance checks have not been carried out. Any reluctance to provide key compliance documents is investigated promptly.

Payments: payments are only made to the contracting entity of our supplier once contractual assurances have been provided that the person performing the services is legally employed or engaged by the entity providing the services; including compliance with relevant labour laws, immigration laws and minimum wage legislation.

Working conditions: red works closely with all our clients to ensure that the working conditions provided at the client site meets the relevant accepted standards. Assurances regarding health & safety are routinely sought and provided.

Governance and oversight

The red group operates an hr department led by the group head of hr, a legal and a head of legal & compliance. All internal audit issues and risk assessment duties are met by the chief financial officer. The group also operates an operations board which includes the country and/or divisional directors within the group, all of whom have reviewed and agreed to the terms of this statement. Each of these departments and executives have reporting responsibilities to management and the various boards of companies within the red group. The red group uses the services of kpmg as its external auditor. A combination of these procedures and functions operates to help identify, assess and monitor potential risk areas in our operations and mitigate the risk of slavery and human trafficking occurring in our supply chains.

The red group companies also articulate a series of employee rights and benefits available to employees in the employee handbooks and individual contracts of employment for each member of staff.

This is the first articulation of a formal anti-slavery policy statement for the red group. In future we will seek to ensure when entering into material contracts that all those in our supply chain and contractors comply with our stated anti-slavery policy in particular when seeking tenders for service or when auditing our suppliers.

Training

We will communicate this statement to all our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business and in future will include references as part of the group’s training and information materials.

Legal and regulatory purpose of this statement

This statement is made with regard to the obligations arising under section 54(1) of the UK's modern slavery act 2015 (the act). This statement should be considered to constitute the slavery and human trafficking statement for red commerce limited and all companies within the red group for the 2017 financial year and all future financial years until it may in future be modified or amended.

Andrew McRae – Chief Executive of the RED Group of Companies
Date: 24.05.2017