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Slavery and Human Trafficking Statement

Working people 2
12 Apr, 2017

Slavery and Human Trafficking Statement

Introduction from the Chief Executive

Brightwork is committed to improving our practices to combat slavery and human trafficking and developing and adopting a proactive approach to tackling hidden labour exploitation.  All sourcing, recruitment and worker placement processes are under the control of trusted and competent employees and we have implemented, and embedded across the organisation, compliance principles to which all our employees are required to adhere.

The company will provide a programme of training to employees, commencing at induction level, which includes awareness workshops on labour exploitation along with methods and best practice guidance on how to identify and deal with potential instances of human trafficking and third party labour exploitation.

Brightwork will adopt a proactive approach to reporting suspicions of hidden worker exploitation and will encourage our workers to report cases of exploitation by providing them with information through leaflets and online communications, along with a safe and confidential means of reporting.  Our employees will be provided with training on how to investigate and act upon any such reports.  The organisations within our supply chain will be required to adopt polices and procedures which are consistent with and uphold Brightwork’s own policies.

We also hope to broaden awareness of the issue by encouraging and providing means to report exploitation which may be occurring in our workers’ wider communities.  During 2016 Brightwork will endeavour to meet the standards required to become a sponsor and partner of the Stronger Together initiative.

Organisation’s Structure

Brightwork was established in 2006 with the management buy out of a division of Hudson Global by the senior management team.  The organisation has expanded with the acquisition and subsequent merging of further businesses from specialist to complimentary recruitment services organisations, thus creating an all-encompassing service offering for Brightwork’s clients.

We are a provider of staffing solutions, with our services including sourcing, screening and appointment of workers for permanent, contract, interim and temporary assignments across a variety of sectors, i.e. logistics and distribution, supply chain, construction, property services, health and social care, hospitality and event catering, manufacturing, warehousing, office and business support services, sales, marketing, retail, engineering, technical, life sciences and production and operations management, operating across Scotland with offices in both Edinburgh and Glasgow.

We had an annual turnover of £33.3 million in 2015.

Our Business

Our business is organised into six business units: Drinks, Manufacturing, Warehousing & Distribution, Property Support Services (including Catering, Cleaning, Facilities, Construction, Property, Health Care and Social Care), Quality Link (hospitality and event catering) and Brightwork Specialist Recruitment (BWSR).

Our Supply Chain

Our supply chain includes:

  • IT systems and support providers;
  • Telecoms providers;
  • Stationers;
  • Waste Management Suppliers;
  • Property Management Agents and Landlords;
  • Legal and Financial Service providers;
  • Job Board and Social Media platform providers.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business.  Our Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

Due Diligence Processes for Slavery and Human Trafficking

As part of our initiative to identify and mitigate risk we will:

  • where viable, build long standing relationships with our suppliers and make clear our expectation of business behaviour;
  • identify and assess potential risk areas in our supply chain (via supplier approval assessment);
  • develop action plans to manage those suppliers which do not participate in or fail the supplier approval assessment;
  • introduce a policy to ensure that workers of a particular nationality are not placed in the hands of an employee of the same nationality;
  • have fixed agenda items regarding the issue included as part of client review meetings;
  • instigate a formal process and documentation for reporting of suspected cases of human trafficking and other types of exploitation;
  • introduce a requirement for workers to be interviewed unaccompanied by any third party, with access to an independent telephone interpreting service (at short notice) to assist in investigations or interviews if required;
  • include on the audit programme a schedule of internal audits for assessing the application and effectiveness of the systems and processes being put in place;
  • protect whistle blowers.

Supplier Adherence to our Values

We have zero tolerance to slavery and human trafficking.  To ensure all those in our supply chain comply with our values we will introduce a rigorous supply chain compliance programme.  This will consist of a supplier approval process which investigates suppliers’ policies, procedures and documentation with regard to tackling and preventing the issue.  The approval process will be repeated at least annually with existing suppliers and be required to be completed as part of the selection process for all new suppliers.  The review will be managed by the Compliance Specialist in conjunction with relevant members of the Executive Board.  Any supplier which comes to Brightwork’s attention for failing to adhere to the Modern Slavery Act 2015 will immediately have their supplier status removed and be reported to the relevant government body.  Any supplier which fails to take a proactive approach towards tackling the issue will be considered for removal and advised of this.

We have created a dedicated compliance team, which consists of the Director for Property and Support Services, the HR Manager and the QA and Compliance Specialist.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chain and our business, we will deliver training to our employees including all consultants including our off-site consultants, reception, administration and procurement teams.  We will also require our suppliers to provide training to their own employees and supply chains.

Our Effectiveness in Tackling Slavery and Human Trafficking

We will use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chain:

  • number of Suppliers contacted and asked to complete the Supplier Approval Questionnaire;
  • number of Suppliers responding and completing the Supplier Approval Questionnaire;
  • number of Suppliers evaluated as acceptable;
  • number of non-conformances raised during internal audits conducted by QA & Compliance Specialist;
  • percentage of workers interviewed who fail the “Right to Work in the UK” validation process;

Further Steps

Following a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chain we intend to take the following further steps to combat slavery and human trafficking:

  • require all organisations within our supply chain to respond to our supplier approval questionnaire and evaluate the responses;
  • approach all organisations within our supply chain which achieve approval status and encourage them to adopt their own anti-slavery policies, providing assistance where necessary and/or requested;
  • collaborate with our key, private sector clients to share and assess anti-slavery policies which they have in place for effectiveness and potential development and improvement of our own policy to align with theirs;
  • develop and deliver a means by which our workers may safely and securely report exploitation occurring in their wider communities.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Slavery and Human Trafficking statement for the financial year ending 31 December 2016.

Derek May, Chief Executive, Brightwork Limited, 17 May 2016


Lynsey Dellett