Anti-slavery and Human Trafficking Statement 2020/21
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Austin Fraser Limited's Anti-Slavery and Human Trafficking Statement for the financial year ending 29 November 2021.
It sets out the steps taken by Austin Fraser Limited, a company registered in England with Company Number 05684470, and other relevant group companies during the financial year to prevent modern slavery and human trafficking in its business and supply chains.
Austin Fraser Limited is a specialist recruitment consultancy in the technology and life sciences sectors. It is the parent company of Austin Fraser, Inc. and Austin Fraser GmbH – together “Austin International”. Austin International employs over 200 people worldwide and has business operations in the UK, the US and Germany. Austin International’s Life Sciences recruitment consultancy trades as Austin Vita.
Opening statement from our CEO
To hold an individual in slavery is a violation of fundamental human rights and a crime. We recognise this takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another for the purposes of exploiting them for personal or commercial gain.
We take a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships and in implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business operations or in any of our supply chains.
We do not believe there is any place in today’s world for slavery or human trafficking. We are committed to continually improving our practices to combat slavery and human trafficking and to encourage the same high standards from our supply chain and other business partners. We choose to engage and partner with like-minded organisations because they recognise that people should be treated with dignity and respect.
Our Employee Code of Conduct makes clear that we expect our own people and everyone employed by our clients and suppliers, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be freely chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice.
We are committed to the highest standards of integrity, transparency and accountability. It is therefore vital to us that we can demonstrate that all appropriate steps are taken to ensure that slavery and human trafficking is not taking place in any of our supply chains or in any part of our own business.
We are publishing this statement to explain the work we have completed to date to combat modern slavery within our business and the steps we intend to take on an ongoing basis.
Our supply chains
As a provider of specialist recruitment services we consider our supply chain to be relatively simple in comparison with many other industries.
We work with a small range of suppliers who provide services across a number of different categories. Therefore, we have close relationships with our suppliers and good visibility of our supply chain. Our supply chains primarily include management companies, job boards, property, media, IT equipment and SaaS suppliers.
We strive to ensure that appropriate supplier checks based around governance and financial standing are always undertaken, and consider these adequate to protect against slavery and human trafficking within our supply chain. This helps to ensure, as far as possible, that no element of the supply chain is involved in human rights violations. As such, we believe that there are no such issues known to be impacting our business, based on both global and localised legislation and the Directors do not consider there to be a risk of slavery or human trafficking taking place within its supplier base.
As part of our commitment to combating modern slavery, we have implemented the following policies in addition to our Anti-Slavery and Human Trafficking Policy:
Whistleblowing policy. We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of Austin International. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
Employee code of conduct. The code makes clear to employees the actions and behaviour expected of them when representing Austin International. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating nationally, internationally and when managing our supply chain.
Our policies are established by our Commercial and Legal team, and in consultation with our HR team. We review our policies annually, or as needed, to adapt to changes.
Due diligence - recruitment services
To reduce the risk of slavery and human trafficking occurring when we are providing recruitment services:
we ensure all workers have a right to work for the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
we take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we ensure all contracts comply with all legal requirements regarding workers’ rights;
where we pay contractor’s limited companies directly, we check that the worker is a director of the company and that such companies have a bank account in their own name into which the remuneration is paid;
where we pay contractors through an umbrella company, we ensure that the umbrella company is a legitimate umbrella company that has been audited by FCSA, APSCo, and/or Professional Passport;
where contractors are on assignment on our clients’ premises, they are always free to leave their assignment; and
contractors receive compliant pay as determined by the Agency Workers Regulations 2011.
In addition, all employees, through the Employee Code of Conduct, are made aware of the requirement for employees to support and uphold human rights principles and know that the Company will not tolerate, engage in or support the use of, forced and/or child labour.
Risk and compliance - procurement
We have evaluated the nature and extent of the exposure to the risk of modern slavery occurring in our supply chain. As our core business is focused on the provision of recruitment services in respect of independent contractors in the fields of Technology and Life Sciences (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high risk sector. That said, when appraising our supply chain, a risk based approach has been developed, focussing on:
Products we buy that are imported from countries identified as having a high risk of modern slavery; and
Services we consume across industries where modern slavery is typically more prevalent.
In terms of the products we buy, we have referred to the Global Slavery Index’s list of products with identified risk of forced labour by source countries. The only risk area identified relevant to our procurement was in relation to electronic devices - laptops, computers and mobile phones. Like many other corporate organisations, we consume products in these areas from globally recognised firms who we require to have established modern slavery policies and practices in place, and we will continue to monitor their activities.
In terms of the services we consume, our risk assessments have determined that cleaning and catering services represents the only service lines which carry a higher risk of modern slavery.
This evaluation process across both categories continues on an annual basis.
In order to mitigate and manage our risk the following activities have been undertaken in the last financial year:
Our Modern Slavery Policy has been reviewed to ensure it is still fit for purpose.
Our Modern Slavery Policy has been shared with all new employees.
Only senior members of staff with an understanding of modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships.
Our staff are encouraged to bring any concerns they have to the attention of senior management.
We do not permit workers to share bank accounts as this can be an indication of illegal or unethical behaviour.
We have not used or accepted forced, bonded or involuntary prison labour or child labour; nor will we hold onto our workers’ identity papers or knowingly work with businesses that do.
No breaches of the Modern Slavery Act were reported during the last financial year.
We review our policies and procedures regularly, not only to ensure they remain relevant, but also to assess our progress.
All employees are expected to comply with all laws and act in accordance with local guidelines and regulations and act with integrity and honesty. All staff are required to read and adhere to our Modern Slavery Policy as part of their induction. Should any of our colleagues need any additional information or support with regard to human trafficking, forced labour, servitude and slavery this will be provided by our Commercial and Legal Manager. Key individuals responsible for approving supplier contracts have undertaken modern slavery awareness training.
Further actions and sign-off
Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:
Deliver refresher training on modern slavery to all relevant employees;
Review our procurement approval process to record steps taken in respect of modern slavery when considering new suppliers;
Provide ongoing support and training to key employees on identifying and minimising the risk of modern slavery in the supply chain.
This Statement is reviewed and signed-off annually by our Chief Executive Officer and Commercial and Legal Director.