What we do
This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 (the “Act”).
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Kelly Group has a zero tolerance approach to any form of modern slavery within our operations or supply chain. We seek excellence in every aspect of our business and are committed to the highest standards of professionalism, ethics and integrity and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Our supply chain relationships
Our key suppliers are the businesses which help us to run our premises, such as our cleaning and security providers, and the businesses which supply us with the technology, products and resources to deliver our services to our clients. We tend to foster long-term relationships with these first-tier suppliers and we avoid making demands of our suppliers that might lead to them violating human rights.
In addition, a proportion of our revenue is spent on subcontractors and materials required to provide our services to our clients. We have relationships with a number of subcontractors and everyday a number of their workers will be working on our sites, in addition to our own employees.
Kelly Group operates a supplier and subcontractor policy and maintains a preferred supplier and subcontractor list. We conduct due diligence on all suppliers and subcontractors before allowing them to become a preferred supplier or subcontractor. This due diligence includes an online search to ensure that a particular organisation has never been convicted of offenses relating to modern slavery.
Our policies on slavery and human trafficking
We remain fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our anti-slavery statement and our internal policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Our internal policies include our No Forced or Bonded Labour Policy where we confirm that we will not tolerate or condone the use of any type of forced or bonded labour within any part of our business or supply chain and will take seriously any allegations that the policy has not been followed or breached. We also operate a Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains, which encourages staff to report any wrongdoing which extends to human rights violation like modern slavery and human trafficking. All reports will be fully investigated and appropriate remedial actions taken.
Due diligence processes for slavery and human trafficking
As part of our initiative we try to identify risks to workers in our supply chain, by regularly refreshing the due diligence we carry out on our key suppliers and subcontractors before we engage them, and through the ongoing supplier and subcontractor management processes we have in place.
When selecting our suppliers and subcontractors, price is not our only driver. We are committed to buying quality products and services from ethical suppliers and subcontractors and part of measuring this involves assessing the approach a potential supplier or subcontractor takes to its people and the workers in its own supply chain.
We have in place systems to:
Our suppliers and subcontractors are also encouraged to report any concerns that slavery human trafficking may be, or is, taking place. Our standard procurement processes include a variety of checks and reviews designed to ensure that the suppliers and subcontractors we engage with have sufficient capability, capacity, and agreement to Kelly Group’s policies and commercial terms.
We are aware that risks arising from modern slavery and human trafficking can apply anywhere in our operations, whether through direct employment, subcontractors or suppliers. As such, we expect our suppliers and subcontractors to ensure that there is no slavery or human trafficking in their supply chain. If any issues are identified that are not resolved to our satisfaction, we will view the on-going relationship with the relevant organisation.
We also have a dedicated compliance team, which consists of involvement from the following departments:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff on how to evaluate suppliers and mitigate risks within supply chains. Our aim is to raise awareness of the issues and increase informed scrutiny. We also actively encourage our staff to report their concerns through their line manager, or any member of the management team.
We understand that modern slavery and human trafficking is not static, and will continue to assess our approach to mitigating this risk in the year ahead and monitor the effectiveness of our actions against modern slavery and human trafficking.
In order to assess the effectiveness of the measures taken by Kelly Group we will be reviewing the following key performance indicators:
We will also continue to develop further standards to support our anti-slavery and human trafficking policy (and related policies). We will keep our supplier and subcontractor policy for the appointment of new suppliers and subcontractors under review, ensure that our workforce continue to receive appropriate training on identifying any potential unlawful or unethical conduct within our operations an supply chain and continue to assess the risks associated with our existing supply chain.
This statement constitutes Kelly Groups slavery and human trafficking statement for the financial year ending December 2017.