INTRODUCTION
This statement is pursuant to Section 54 of the Modern Slavery Act 2015 and sets out Jonathan Lee Recruitment Limited and Jonathan Lee Contracts Limited (JLR) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
As part of the recruitment and engineering sectors, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
We are also signatories to the UN Global Compact and have agreed to adhere to the UN’s guiding principles, which means we have stated that we will work to protect human rights in our business and those businesses we work with.
CURRENT POSITION
- JLR is a recruitment business providing staffing services to companies in the engineering sector. We deliver both permanent and contract-based recruitment services to our clients.
- Our supply chain is minimal and solely relates to the operation of the business and services to our clients and contractors
- The organisation currently operates in the UK – all current operations for JLR are in the UK, as such we do not believe we operate in a “high-risk” location for Modern Slavery. Whilst we operate in the recruitment sector, which can be considered “high-risk” in some facets such as “agency workers”. Our focus on engineering and particularly skilled engineering roles, means that our market is considered by JLR’s management team to be “low-risk”.
- We are active members of our UK trade body – Recruitment & Employment Confederation (REC) and ensure all our policies and procedures meet or exceed their levels.
- Responsibility for the organisation’s anti-slavery initiatives is the Managing Director and through him to the operational managers of the business.
- The organisation undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers.
- The organisation operates a range of policies to ensure it complies with the Modern Slavery Act; as noted these are checked via our trade body and meet at least their minimum standards.
WHISTLEBLOWING POLICY
The organisation encourages all its workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers, or others who have concerns can take their concerns to the Managing Director/Chairman.
EMPLOYEE CODE OF CONDUCT
The organisation’s code 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.
SUPPLIER CODE OF CONDUCT
The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics.
ACTIONS FOR 2024
This due diligence on suppliers is currently in relation to a wide range of issues and will include reviews on actions/statements in relation to the Modern Slavery Act from January 2024.
- Whilst as an organisation we believe we are in a low-risk environment, during 2024 we will
implement further staff training to ensure all staff are fully aware of the Modern Slavery
Act 2015 and both their personal and the organisation’s responsibilities under the act. This
will include areas such as:
- How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
- 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 organisation.
- What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.
• In addition, during 2024 management will undertake to review what steps the organisation
should take if suppliers or contractors do not implement anti-slavery policies in high-risk
scenarios, up to and including their removal from the organisation’s supply chains.
• As well as training staff, during 2024 the organisation will circulate a series of emails to
staff to cover:
- The basic principles of the Modern Slavery Act 2015.
- How employers can identify and prevent slavery and human trafficking.
- What employees can do to flag up potential slavery or human trafficking issues
to the relevant parties within the organisation.
- What help is available within the business and how to access it.
APPROVAL
This statement has been approved by the organisation’s Board of Directors who will review it
annually.
DAVID HALE
Managing Director
Date: March 2024
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