Modern Slavery Policy

Modern Slavery Statement

Stanton House Limited is a company registered in England & Wales under company number 07394702, whose registered office is at 2nd Floor, 25 Christopher Street, London EC2A 2BS.

 

This statement is made pursuant to section 54 of the Modern Slavery Act 2015. It constitutes Stanton House’s slavery and human trafficking statement for the financial year ending December 2023. 

This statement covers the activities of Stanton House Limited.

Our Organisation 

Stanton House Ltd is a private limited company incorporated in the UK. Stanton House is a recruitment company with approximately 50 staff based mainly in the UK. Our staff are directly employed and are not in any category that is seen to be vulnerable to modern slavery. 

Our main focus is to ensure there are policies and due diligence in place for our suppliers. 

Supply Chain 

The company’s principal suppliers are technology providers and service providers, mainly based in the UK. We have devised and implemented a code of conduct for our suppliers. 

Suppliers shall at all times comply with this code and with the applicable national and international laws, regulations, codes and standards, both in the country in which the supplier works and in the country in which the product and/or services are sourced/provided.

Suppliers shall ensure, as far as is reasonably practicable, that their suppliers, agent(s), subcontractors and consultants, who are directly or indirectly involved in the provision of goods and/or services to Stanton House Limited comply with the code. 

Suppliers shall ensure: 

Employment is freely chosen

  • There is no forced, bonded or involuntary prison labour.

  • Workers are not required to lodge monetary deposits or their identity papers with their employer and are free to leave their employment after reasonable notice.

Freedom of association and the right to collective bargaining respected 

  • Workers have the right to join or form trade unions of their own choosing and to bargain collectively. 

  • The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 

  • Workers’ representatives are not discriminated against and have access to carry out their representative functions in the workplace.

  • Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates and does not hinder the development of parallel means for independent and free association. 

Working conditions are safe and hygienic

  • A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of industry and of any specific hazards. 

  • Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as reasonably practicable the causes of hazards inherent in the working environments. 

  • Workers shall receive regular recorded health and safety training. 

  • Workers are provided with access to clean toilet facilities and to safe drinking water, and, if appropriate sanitary facilities for food storage shall be provided.

  • Accommodation where provided, shall be clean, safe and meet the basic needs of the workers. 

  • A senior management representative shall be responsible for Health and Safety.

Child labour shall not be used 

  • There shall be no use of child labour. 

  • In the event of any child found to be performing child labour, they shall be removed from the workplace immediately. The supplier shall then participate and contribute to the provision for the transition of the child to enable her or him to attend quality education until no longer a child. 

  • Young persons under 18 shall not be employed at night or in hazardous conditions. 

  • These policies and procedures relating to Child Labour shall conform to the provisions of the relevant International Labour Organisation (ILO) Standards.

Remuneration 

  • Wages and benefits paid for a standard working week meet, at a minimum, national legal or industry benchmark standards, whichever is higher. In any event wages shall always be enough to meet basic needs and to provide some discretionary income. 

  • All workers shall be provided with written and understandable information about their employment conditions including information with respect to wages before they enter employment, and about the particulars of their wages for the pay period concerned each time they are paid.

  • Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded. 

Working hours are not excessive

  • Working hours must comply with national laws, collective agreements, and the provisions defined in the clauses below, whichever affords the greater protection for workers. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.

  • All overtime shall be voluntary. 

  • Overtime shall be used responsibly, taking into account all the following: the extent, the frequency and hours worked by individual workers and the workforce as a whole. It shall be used to replace regular employment. 

  • Workers shall be provided at least one day off every 7-day period or, where allowed by national law, 2 days off in every 14-day period.

No discrimination is practised 

  • There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, national origin, religion, age disability, gender, marital status, sexual orientation, union membership, or political affiliation.

Staff

Regular employment is provided 

  • To every extent possible work performed must be on the basis of recognised employment relationships established through national law and practice. 

  • Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour only contracting, sub-contracting and home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment. 

No harsh or inhumane treatment is allowed

  • Suppliers provide a workplace in which any form of harassment is unacceptable. Examples include physical abuse or discipline, the threat of physical abuse or sexual or other harassment and verbal abuse or other forms of intimidations. 

Entitlement to work 

  • Only workers with a legal right to work in the country should be employed.

  • For both workers and agency workers, original documents should be reviewed and then returned to workers to verify the right to work. 

Labour Providers 

  • Labour providers should only supply workers registered with them. 

  • Relationships with labour providers should be covered by a Service Level Agreement which meets all national legal requirements. 

  • Labour providers should be independently audited on a regular basis to ensure compliance with national requirements/legislation.

Staff 

Stanton House has a framework of values, rules and behaviours that enables the reporting of any concerns confidentially and anonymously if they wish. All staff are trained in the provisions of the Modern Slavery Act.

Our approach 

We will continue to explore how we can enhance our procedures to help us mitigate risks associated with modern slavery or human trafficking. 

Approval 

This statement has been formally approved by the Board of Stanton House Limited.