Modern Day Slavery Policy

Recoup Financial Solutions Limited fully committed to the prevention of Modern Slavery and Human Trafficking and will not tolerate or condone any such identified act within our operations or supply chains.

In accordance with the 2015 Modern Slavery Act, this statement sets out the steps we have undertaken as a business in the prevention of Modern Slavery or Human Trafficking within our operations or supply chains.

We are committed to fulfilling our obligations under the Modern Slavery Act and to continue using our influence to increase transparency on this issue to protect vulnerable workers and prevent human rights violations.

We do not tolerate forced labour, child labour, threats, coercion, abuse, violence, or intimidation among our employees or in our supply chain.

We believe Modern Slavery risks are exceptionally low within our direct operations.

Introduction

Modern Slavery is a growing problem globally, more prevalent in some geographies and sectors than others. However, we realise that no sector or industry is exempt from this crime. Modern Slavery takes many forms including:

·        Forced labour – forced to work under the threat of some form of punishment.

·        Debt bondage or bonded labour – when a person is forced to work to pay off a debt or other obligation. The world’s most widespread form of slavery.

·        Human trafficking – transporting, recruiting people for exploitation, using coercion.

·        Descent-based slavery – people born into slavery because their parents or other family members are/were enslaved.

·        Child slavery – Not just child labour but child trafficking, child soldiers, child domestic slavery or child marriage.

Organisational Structure

Recoup Financial Solutions is the commercial brand of Recoup Financial Solutions Ltd a privately-owned business

Headquartered:

Unit F3-F4 Scope House

Weston Road

Crewe

CW1 6DD

Telephone Number: 01270 500602

Email: info@recoupfinancialsolutions.co.uk

Recoup Financial Solutions provides a diverse range of business support services & training solutions to businesses customers in the UK, including small businesses, large businesses, governments, and charities. Our work is conducted solely in the United Kingdom and the Isle of Man and is delivered by a workforce all of whom are fully eligible to work within the United Kingdom.

Supply Chain

The products and services provided by Recoup Financial Solutions does not require a global supply chain. We consider that any exposure to the risk of Modern Slavery or Human Trafficking is extremely low and that should any risk exist it is most likely to be within the extended Supply Chain, nevertheless, we review our supply chains to ensure the potential for slavery and human trafficking is reduced.

We work closely with members of our Supply Chain in the identification of such risk to ensure it is addressed appropriately. We tell the companies we do business with that we are not prepared to accept any form of exploitation.

Our Terms and Conditions of Business contain an anti-slavery clause. This clause prohibits suppliers and their employees from engaging in slavery or human trafficking if they want to do business with us. Plus, we provide training in Modern Day Slavery to private and public sector businesses.

Modern Slavery Policies

Recoup Financial Solutions Limited has implemented a comprehensive policy in respect of the prevention of Modern Slavery and Human Trafficking. This policy details our approach to the prevention of Modern Slavery and Human Trafficking, along with the processes used to support and deliver our commitment. This policy and commitment have been communicated to our employees for their information and action.

We operate a risk-based approach to the identification of Slavery and Human Trafficking the principle of which is based in the location of the product or service, industry sector, supplier relationships, and existing data held supported by additional information guidance obtained.

Identification of Risk

Recoup Financial Solutions Limited Supply Chain is primarily UK based, we have instigated a risk assessment of supply chain activities to identify and prioritise any areas where we can add most leverage in respect of the prevention of Modern Slavery.

Recoup Financial Solutions Limited’s policy of direct employment is supported by robust processes, which ensures that an individual’s identity is confirmed, and they have a legitimate right to work in the United Kingdom. This policy and the right to work checks undertaken by our employees minimise the risk of employing forced labour or those who may be subject to human trafficking.

We take the following actions when recruiting:

Recruiting Directly

1.   We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.

2.   We always ensure staff are legally able to work in the country in which they are recruited.

3.   We check the names and addresses of our staff (several people listing the same address may indicate high shared occupancy, often a factor for those being exploited).

4.   We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.

5.   If through our recruitment process, we suspect someone is being exploited, the HR Department will follow our reporting procedures.

6.   We conduct due diligence checks on any recruitment agency that we use to ensure that it is reputable and conducts appropriate checks on all staff that they supply to us.

7.   If through our recruitment process, we suspect someone is being exploited, we will follow our reporting procedures
Recruitment using agencies.

8.   We also employ staff from government schemes like the Kickstart Scheme.

Risk assessment

As a UK based Business Support Service, neither our sector nor our operating location is areas of high risk.

Internal Risk

Assessment: Exceptionally low

Our people are key to the success of our business, so we invest heavily to make Recoup Financial Solutions a workplace of choice. We believe employee diversity and inclusion and the different perspectives it brings gives us a competitive advantage. When recruiting new staff or in the course of employment of existing staff.

We treat all people fairly and impartially, without prejudices related to race, colour, nationality, ethnic origin, religion, gender, sexual orientation, marital status, age, political affiliation, disability or family responsibilities and we set our pay and rewards packages to attract the market’s best talent.

We recruit and manage employees against a range of policies designed to create a unique and diverse environment. Our supportive policies such as maternity, paternity, adoption leave, and flexible working make Recoup Financial Solutions accessible to all.

Internal employee engagement surveys as well as external reference points, such as awards, show that Recoup Financial Solutions is a workplace of choice. We, therefore, perceive internal risks to be exceptionally low.

External Risks

Assessment – Low

Recoup Financial Solutions has NO non-domestic suppliers that operate in both at-risk sectors and at-risk geographies.

Due Diligence

Domestic (UK Based) due diligence.

Domestic suppliers’ assessment is in place for any third party used be Recoup Financial Solutions Ltd. We complete intense Due diligence before contracts are signed with suppliers and during a contract’s term.

Communication and Training

Recoup Financial Solutions Limited commitment to the prevention of Modern Slavery and Human Trafficking emanates directly from our Board of Directors. Their leadership and commitment to this important social issue have been communicated both internally to employees and externally to subcontractors and supply chain partners. 

Recoup Financial Solutions has also been a lead on several local Events highlighting the issue of Modern Slavery and Human Trafficking and the 17 different types of criminality associated with Modern Slavery within the Cheshire Area. Plus, we provide training in Modern Day Slavery to private and public sector businesses.

All employees who have direct responsibility and involvement for the engagement of workers and for dealing with supply chain matters have received appropriate levels of training in these issues.

All employees of Recoup Financial Solutions must complete a training course on the Modern Slavery Act 2015 on induction and annually thereafter.

Governance

Our board is responsible for approving and monitoring our commitments to upholding the principles of the Modern Slavery Act 2015.

Acknowledgement

We acknowledge that we are in the early stages of a long-term process and our approach to the Prevention of Modern Slavery and Human Trafficking will undoubtedly change year on year. We will utilise our annual statements to reaffirm our continued commitment and communicate this evolution including the steps we have taken and will continue to take to deal with this socially important issue.

Reporting any concerns

We encourage anyone with concerns about Modern Slavery relating to Recoup Financial Solutions ltd to email compliance@recoupfinancialsolutions.co.uk.

This facility allows suppliers and members of the public to ask questions, make suggestions, report incidents, or lodge complaints.

We also support employees when faced with ethical dilemmas. Our approach is designed to encourage a culture of honesty and openness whereby our people are confident to raise matters that may be of concern to them.

Employees with any concern are also requested to contact the managing director in in confidence via email to info@recoupfinancialsolutions.co.uk.

Looking ahead

We will continue to integrate Modern Slavery risk management into our routine sustainability management approach. We will also look at means to grow the level and depth of our supply chain due diligence.