Modern Slavery Act Statement 2021

Each year we publish a transparency statement in accordance with the Modern Slavery Act 2015 which sets out the steps taken by us to prevent modern slavery and human trafficking in our business and supply chains during that year. Our most recent statement is dated 26th October 2021.

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by GCS Associates (“we” or “our”) to prevent modern slavery and human trafficking in its business and supply chains.

Our Business:
We have a zero-tolerance approach to modern slavery and human trafficking within our business and supply chains. GCS Associates  is the UKs leading talent solutions and recruitment company within the Construction Supplies, Hire, Builders Merchant & Manufacturing sectors. Our 360° solutions offering enables sustainable and lifelong employability for individuals and empowers organisations to optimise their workforces. We lead by example, creating shared value that meets social needs whilst driving business innovation.

This statement forms a key part of our sustainability strategy: to lead the way as a socially responsible business.

Responsibility
Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: Our HR team is responsible for putting in place and reviewing
  • Investigations/due diligence: Our HR team is responsible for investigations and work closely with our Compliance team in relation to due diligence and checks
  • Training: Our training and compliance team provide training on all policies and procedures, ensuring all staff have undergone ‘Stronger Together’ training. This is reviewed regularly with regular updates and questionnaires issued to all staff members.
    All temporary workers are shown the ‘Stronger Together – Daniel and Weronika’ video at induction stage with posters visible at all sites. We also randomly interview workers every month at all sites where temporary staff are provided to assist in tackling any issues.

Relevant Policies
The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • 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 use our confidential reporting service through the ‘Stronger Together’ initiative;
  • 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 when operating abroad and managing its supply chain.

Due Diligence
The organisation undertakes due diligence when considering taking on new Clients, and regularly reviews its existing Clients. The organisation’s due diligence and reviews:

  • evaluating the modern slavery and human trafficking risks of each new Client;
  • conducting branch and on-site facility audits through the organisation’s own internal auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • taking steps to improve Clients’ practices, including providing advice to Clients through our trained management team and requiring them to implement action plans such as on-site surgeries and displaying of ‘Stronger Together’ information;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular “Stronger together” and “Ethical trading” initiatives.

Training
The organisation requires all staff working within the organisation to complete training on modern slavery. This has taken place for all existing staff and new staff undertake the training during the first week of their employment with us. The organisation’s modern slavery training covers:

  • 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 external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative.

Awareness-raising programme
As well as training staff, the organisation has raised awareness of modern slavery issues by putting up posters across the organisation’s premises and on-site facilities as well as advising during inductions prior to them beginning any assignments.

The posters explain to staff:

  • 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; and
  • what external help is available, for example through the Modern Slavery Helpline.

Further Steps
As a business, we are committed to building on what we do each year to prevent modern slavery and
human trafficking. Following a review of the effectiveness of the actions we have implemented, in 2021 we
intend to:

1. Continue to provide training to all new staff;
2. Progress our dialogue with our clients by offering support, information and training;
3. Conduct regular analysis of our workers’ records to ensure risk areas such as multiple workers having the
same contact telephone numbers, address or bank details are identified and investigated;
4. Continue our audit of our suppliers;

This statement was approved by GCS Directors on 26th October 2021 and is made pursuant to section
54(1) of the Modern Slavery Act 2015.