Modern Slavery Statement

At Fortress Recruitment Services Limited, we are committed to conducting our business with the highest standards of ethics, integrity, and transparency. As part of our commitment to responsible business practices, we are dedicated to ensuring that modern slavery and human trafficking do not occur within our operations or supply chains.

This statement outlines our approach to preventing modern slavery in line with the requirements of the Modern Slavery Act 2015. It highlights the steps we are taking to identify, address, and mitigate the risks of modern slavery within our business, and our ongoing commitment to maintaining a fair, transparent, and accountable environment for our employees, contractors, and clients.

We recognise the serious impact that modern slavery can have on individuals and society, and we take this responsibility seriously. Our values guide us in fostering a culture of respect, fairness, and inclusion, and we continuously review our policies and procedures to safeguard against any form of exploitation or coercion.

This statement applies to all of our operations, including those of our subsidiaries, and reflects the actions we have taken and will continue to take to prevent modern slavery in all its forms.

Matthew Wrainwright
Director

January 2025

Fortress Recruitment Services Limited (“the Company”) is a specialist recruitment consultancy based in the UK.

As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

We work with a small range of suppliers who provide services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain.

We have evaluated the nature and extent of the Company’s exposure to the risk of modern slavery occurring in its supply chain.  We do not consider that we operate in a particularly high risk sector. Our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (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).  When appraising our supply chain, a risk based approach has been developed, focussing on:

1. a) products we buy that are imported from countries identified as having a high risk of Modern Slavery; and
   b) services we consume across industries where modern slavery is typically more prevalent.

In terms of the products we buy, we have referred to the 2023 Global Slavery Index’s list of products with identified risk of forced labour by source countries. The only product areas identified as presenting a higher risk of modern slavery to the Company were:

•  Electronics – Laptops, peripheral devices and mobile phones.

In terms of the services we consume, our risk assessments have determined that cleaning, couriers and confidential waste disposal services represent the only service lines that carry a higher risk of modern slavery.

The Company, like with many other corporate organisations typically consumes products and services in these areas from globally recognised firms who we require to have established modern slavery policies and practices in place, and we continue to monitor their activities on an annual basis. To provide additional assurance, we have undertaken enhanced due diligence on our UK suppliers over the past 6 months across these risk areas to ensure they can all exhibit one or more of the following criteria and in doing so underlining their commitment to and controls over modern slavery:

1. Hold a globally recognised sustainability rating by Ecovadis of at least Bronze or above (these assessments rate businesses based on labour and human rights standard, ethics, procurement practices and environmental impacts).
2. Accreditation such as ISO9001, ISO14001 or ISO45001 which require organisations amongst other criteria to implement effective processes for the control of external suppliers of raw materials/ outsourced services.
3. Provide products which are PEFC  or FSC  certified.
4. Disclose their own standards and obligations placed on supply chain partners within a Modern Slavery Statement or Supplier Code of Conduct.

This evaluation process across both categories continues an annual basis.

https://www.globalslaveryindex.org

Our employees are required to comply with our Employee Code of Conduct (LINK) and our suppliers with our Supplier Code of Conduct (LINK).

These policies reflect our commitment to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our business and UK supply chain.

The Company prohibits and condemns the use of all forms of forced labour including child labour and any form of human trafficking as set out in the Employee Code of Conduct (LINK). We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” initiative which employees and third party workers are encouraged to report any concerns,

As part of our own business we supply temporary personnel to a number of clients. We take our obligations seriously in this respect and have well established procedures to ensure that those temporary workers are protected from the risks of modern slavery. As an example, we ensure that:

• temporary 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 carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
• where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
• where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
• temporary workers 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 labour.

We recognise the role our employees can play in helping to identify modern slavery risks in the supply chain, and in response to this have trained our staff to spot concerns.
Alongside incorporating due diligence queries in our UK RFP processes to identify our potential suppliers’ approach to modern slavery and risk profile, we have embedded enhancements to our onboarding process to request all prospective vendors to provide further assurance on their approach to human rights. Where relevant, we aim to ensure supplier contracts include an obligation on suppliers to comply with the Modern Slavery Act 2015 and where appropriate also include rights of audit to help us identify unethical practices.  If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to either remedy such non-compliance or terminate our relationship.

This approach is designed to:

• identify and assess potential risk areas in our supply chain;
• mitigate the risk of slavery and human trafficking occurring in the supply chain;
• monitor potential risk areas in the supply chain; and
• provide adequate protection to whistle blowers.

There were no instances of modern slavery reported in 2024.

Following a review of the effectiveness of the steps taken in the previous financial year to prevent modern slavery or human trafficking occurring in our business, we intend to take the following further steps during the course of the 2025 financial year:

• Deliver Ethical Procurement training to staff
• Ensure our business continues to monitor, manage and report modern slavery risks in accordance with the modern slavery playbook.
• Investigate the viability of providing online modern slavery training to our Suppliers and employees to further raise awareness of modern slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the year ending 31 December 2024.
Matthew Wrainwright, Director
Fortress Recruitment Services Limited