Modern Slavery Act is an important piece of legislation, here's how we ensure compliance.
This statement sets out Exact Payroll Limited (Exact) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As an initial statement, this statement relates to actions and activities during the current financial year (1 April 2019 to 31 March 2020).
Exact is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
Exact is a UK based payroll services provider, focused on helping our clients deliver excellent recruitment services. This means working in partnership with our clients to create a workplace culture that recognises employee wellbeing as being at the heart of business success.
Applying multidisciplinary expertise and deep industry knowledge, our Exact specialists work exclusively with UK clients from construction, teaching and healthcare sectors, including financial services and transport.
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
Exact operates a supplier policy and undertakes due diligence on all our suppliers. The due diligence includes a statement that each supplier is required to complete to show that the organisation:
Complies with the Modern Slavery Act;
Takes steps to eradicate modern slavery from their business
Holds their own suppliers to account over modern slavery
Ensures their workers receive the minimum wage and undertake robust immigration checks
We may terminate the contract at any time should any instances of modern slavery come to light.
Exact does not consider it operates in high risk sectors or locations as we only operate within the UK and utilise predominantly professional employees.
- Recruitment: Exact follow a Recruitment Policy and Procedure and have strict Security Guidelines in place to support the recruitment process. The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Grievances: Exact has a documented Grievance Procedure for the reporting of unlawful discrimination in any form.
- Learning and Development: Exact has a Learning and Development Policy to ensure the required development of staff through communication and training opportunity.
- Whistleblowing policy: The organisation encourages all its workers 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 whistle blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Anti slavery policy: This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where to go for help.
- 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.
The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:
- evaluating the modern slavery and human trafficking risks of each new supplier;
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- conducting supplier audits or assessments through the organisation's own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
- taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation:
- has a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
- reviews existing supply chains to ensure ongoing compliance.
The organisation requires Supply Chain managers, Procurement Managers, recruitment and HR professionals within the organisation to complete training on modern slavery.
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;
- what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.
As well as training ‘key’ staff, the organisation is also raising awareness of modern slavery issues by developing information for cascading and circulating in our employee newsletter known as Informed.
- the basic principles of the Modern Slavery Act 2015;
- how employees 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.
This statement has been approved by the organisation's Board of Directors who will review and update it annually.
Signed: Lisa Barnwell Tully, Director
Exact Payroll Limited
Date: October 2022