Modern Slavery policy

What is modern slavery?

Labour exploitation

• Sexual exploitation

• Domestic servitude

• Organ harvesting

• Criminal exploitation

• Victims are controlled by force, threats, coercion, abduction, fraud and deception.

How to spot the signs :

Restricted freedom

Victims may:

• Not be in possession of their passports or other travel or identity documents, as those documents are being held by someone else

• Be unable to leave their work environment

• Show signs that their movements are being controlled

• Be unable to move freely

• Be threatened with being handed over to the authorities

• Be subject to security measures and controls to keep them on the work premises

• Depend on their employer for work, transport and accommodation without any choice

• Be controlled through religion, witchcraft, juju etc

• Have limited contact with their families or with people outside of their immediate environment

• Be unable to communicate freely with others

• Be forced to shop at a place they would not choose

• Have no access to medical care

• Be in a situation of dependence

• Be given only leftovers to eat

• Come from a place known to be a source of human trafficking

• Be subjected to violence or threats of violence against themselves or against their family members and loved ones

• Be found in or connected to a type of location likely to be used for exploiting people

• Have false identity documents


Victims may:

• Be unfamiliar with the local language

• Act as if they were instructed by someone else

• Allow others to speak for them when addressed directly

• Be distrustful of the authorities

• Be afraid of revealing their immigration status

• Have limited or no social interaction either in the workplace or at their accommodation

• Believe that they must work against their will

• Never leave the workplace without their employer

• Show fear or anxiety

• Feel that they cannot leave

• Have to resort to crime in order to get food or money for food

• May need to scavenge for food

• Be forced to commit crime if there is no work available for them

• Have acted on the basis of false promises

Working conditions

Victims may:

• Have no contract

• Be unable to negotiate working conditions

• Be unable to choose when or where they work

• Be forced to work under certain conditions

• Work excessively long hours over long periods

• Not have any days off

• Not be dressed adequately for the work they do: for example, they may lack protective

equipment or warm clothing

• Lack basic training or professional licences


Victims may:

• Not know their home or work address

• Not have been able to give their address to friends or relatives

• Live in poor or substandard accommodation

• Have no choice where they live or who they live with

• Live in groups in the same place where they work and leave those places infrequently, if at all

• Live in degrading, unsuitable places, such as agricultural or industrial buildings


Victims may:

• Receive little or no payment

• Have no access to their earnings

• Be disciplined through punishment or fines

• Be under the perception that they are bonded by debt

• Have had the fees for their transport to the country of destination paid for by facilitators, whom they must payback by working or providing services in the destination

• Be told that they can pay debts for transport or accommodation when they are found work

• Be charged for services they don’t want or need

• Be forced to open bank accounts

• Be forced to sign documents to receive social security benefits, credit agreements or loans


Victims may:

• Suffer injuries that appear to be the result of an assault

• Suffer injuries or impairments typical of certain jobs or control measures

• Suffer injuries that appear to be the result of the application of control measures

If you believe that somebody is being exploited, please flag this up with Rebecca Richardson- Director or Kim Moey- Office & Compliance Manager.

Our Modern Slavery Policy

​1. Smith & Reed Recruitment (SW) Ltd is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.

2. Smith & Reed Recruitment (SW) Ltd is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

3. Smith & Reed Recruitment (SW) Ltd provides appropriate training and awareness information for all staff.

In particular:

All of our staff receives 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.

4. Any staff, workers or other parties are strongly encouraged to report any concerns or

suspicions that they might have to either Rebecca Richardson - Director or Kim Moey - Office and Compliance Manager.

5. Reports surrounding these issues are taken extremely seriously by the senior leadership team who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

• Working with the appropriate organisations to improve standards,

• Passing details to appropriate law enforcement bodies.

6. As part of our efforts in this area, we publish a modern slavery statement on an annual basis.

This policy was adopted on January 2016 after being agreed by our Directors and is reviewed every financial year.