Human Trafficking Statement

Modern slavery

is a violation of fundamental human rights and encompasses slavery, servitude, forced and compulsory labour, and human trafficking.

Introduction
  • We are Campion Willcocks Limited of Oakfield House, 59 Hill Avenue, Amersham, Buckinghamshire HP6 5ED.
  • This Slavery and Human Trafficking Statement is made for the financial year ending 31 st October 2018.
  • Modern slavery is a violation of fundamental human rights and encompasses slavery, servitude, forced and compulsory labour, and human trafficking.
  • Campion Willcocks has a zero tolerance approach to modern slavery and this statement sets out the steps that our organisation has taken, and continues to take, to minimise the risk of slavery and human trafficking taking place in any part of our business or our supply chain.
  • In summary, we continually review our policies, processes and procedures to ensure that they address the risks posed by modern slavery.
  • The person in our organisation with overall responsibility for ensuring that all necessary steps are taken to combat slavery and human trafficking is Richard Clifford, Managing Director.
Business structure
  • Campion Willcocks operates within the recruitment sector in the UK and acts as an employment agency, employment business, and consultancy. We provide recruitment and consultancy services to our clients, namely introducing and/or supplying change management professionals mainly in the financial services sector.
  • The average number of employees for the year was 40 with an annual turnover of £36,326,925.
  • Our contractors and consultants are predominantly based in the UK and they all provide services via UK limited companies on which a number of due diligence checks are undertaken.
  • Our supply chains consist of suppliers of personnel with whom we work to deliver services to clients.
Policy
  • We respect and support the principles outlined in the ILO Declaration on Fundamental Principles and Rights at Work: freedom of association, elimination of all forms of forced or compulsory labour, effective abolition of child labour, and elimination of discrimination in employment and occupation.
Training
  • Campion Willcocks provides all employees with training on an annual basis and during induction on the risks posed by modern slavery and the processes and procedures designed to combat it within the organisation and supply chain.
Due diligence processes for slavery and human trafficking
  • As part of Campion Willcocks’ zero tolerance approach to slavery and human trafficking and as part of our initiative to identify and mitigate risk, we have specific systems and processes in place which are focussed on recognising and carefully assessing potential risk areas in our supply chain and within our organisation.
  • We understand that no part of our business is completely immune to the risk of modern slavery.
  • Within the recruitment sector, however, we have assessed the risk of modern slavery occurring within our business and supply chains as lower than average risk. We supply professional, experienced limited company contractors to organisations operating mainly within the financial services sector. We do not supply personnel to any organisations operating within any high risk sectors, such as domestic, care, entertainment, hospitality, manufacturing, agriculture or construction.
  • We do recognise, however, that in respect of goods and services supplied to us, such as cleaning services, there is a higher risk of modern slavery.
  • As a recruitment business we already have a number of specific processes and systems in place which are either required by law, or recommended as best practice, many of which also assist in identifying and minimising the risk of modern slavery. These include:
    • undertaking ID and address checks
    • obtaining references
    • checking right to work in the UK
    • verifying payment arrangements
  • We continue to review our existing internal processes to ensure compliance and to minimise the risk of modern slavery taking place within our organisation and supply chains.
  • All our employees are aware of our Whistleblowing Policy which can be found in our Employee Handbook, and the processes in place. Employees are encouraged to report any concerns or suspicions regarding slavery or human trafficking to management. Employees are aware that no employee will suffer any detriment as a result of disclosing a concern relating to slavery or human trafficking in good faith.
Further steps
  • To ensure that Campion Willcocks’ practices are as effective as possible, we continue to review our strategies for minimising the risk of modern slavery within our business and supply chains.
Key performance indicators
  • Campion Willcocks will monitor the indicators below to assess the effectiveness of the steps that we are taking to combat modern slavery
    Completion of training
    Reports of occurrence or potential occurrences of modern slavery
  • This statement has been approved by Campion Willcocks’ board of directors and constitutes our Slavery and Human Trafficking Statement pursuant to Section 54 of the Modern Slavery Act 2015, for the financial year ending 31 st October 2018.