Modern Slavery

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This statement is made as part of Acuity Applied commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Acuity Applied operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act, and relates to the financial year April 2021 to March 2022. 

1. Our Business

Acuity Applied is a limited company operating in the consulting and recruitment sector. We provide introduction services and supply temporary workers and consultants in the Analytics, Digital, Information Security, Technology and Telecom sectors.

Acuity Applied Limited is an independent business.

2. Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies. Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.

The hiring companies that we work with are generally located in Europe and the USA. The workers we supply generally live in United Kingdom, Europe and the USA.

3. Our Policies

In addition, Acuity Applied Limited has the following policies which incorporate ethical standards for our staff.

• Corporate social responsibility policy,
• Ethical business practices,
• Ethical trading initiatives,
• Anti-bribery, and
• Human rights policy.

4. Policy development and review

Acuity Applied Limited policies are established by our senior leadership team, based on advice from HR professionals, industry best practice, and in consultation with Group Legal Counsel. We review our policies annually, or as needed to adapt to changes.

5. Our Processes for Managing Risk

Policies, processes and procedures are in place in order to:

• Mitigate the risk of slavery and human trafficking occurring within Acuity Applied Limited by ensuring full compliance with UK Visas and Immigration (UKVI) “right to work” checks;
• Monitor and address any emerging issues of concern and protect whistleblowers.
• In order to assess the risk of modern slavery, we use the following processes with our suppliers:
• When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistleblowing.
• We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.
• After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.
• Additionally, we have taken the following steps to minimise the possibility of any problems:
• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
• We require the businesses we work with to publish a modern slavery statement.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.

Our staff are encouraged to bring any concerns they have to the attention of management.

6. Our Performance

Based on the potential risks we have identified, we have established the following key performance indicators, which are regularly assessed by our board of directors:

• the percentage of suppliers who provide their own modern slavery statements
• the percentage of candidates engaged through our preferred supplier list
• the effectiveness of enforcement against suppliers who breach policies
• the amount of time spent on audits, re-audits, spot checks, and related due diligence
• the level of modern slavery training and awareness amongst our staff

We benchmark our indicators against industry best-practice in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

7. Our Training

Our staff receive training and support that is appropriate to their role. In particular:

• Our leadership team receive training in identifying and resolving concerns around modern slavery and human trafficking.
• Our recruiters, HR personnel, and staff involved in our procurement and supply chains undertake training that includes guidance around modern slavery and human trafficking, as well as other wider human rights issues.
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this our staff are encouraged to discuss any concerns that they have, and training is refreshed regularly as necessary.

Kram Ali, Director, Acuity Applied Limited