Modern Slavery Policy

Summit Computer Recruitment Ltd t/a itecopeople is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
Summit Computer Recruitment Ltd t/a itecopeople is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
Summit Computer Recruitment Ltd t/a itecopeople provides appropriate training and awareness information for all of its staff. In particular:
- All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to Simon Dunscombe – Managing Director.
Reports surrounding these issues are taken extremely seriously by our directors (Simon Dunscombe – Managing Director; Sharon Dunscombe – Finance Director), who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
- Working with the appropriate organisations to improve standards,
- Passing details to appropriate law enforcement bodies.
We regularly monitor our risks in this area through the use of relevant key performance indicators.
We would also recommend reading this in conjunction with our other policies, including our:
- Corporate social responsibility policy
- Ethical procurement policy,
- Anti-bribery / corruption policy.

This policy was adopted on 22nd January 2018 after being agreed by our board of directors. It is reviewed annually.

Modern Slavery Statement

This statement is made as part of itecopeople’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how itecopeople operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.

This statement is published in accordance with section 54 of the Act, and relates to the financial year 01/2019 to 12/2019. It was approved by the board of directors / the partners on 22/01/2019.

Simon Dunscombe
Managing Director

1: Our Business

Summit Computer Recruitment Ltd t/a itecopeople is a limited company operating in the recruitment sector. We supply contractors and permanent staff in the IT and Senior Management sectors.

itecopeople is an independent business.

1.1: Who we work with

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff. All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies.

The hiring companies that we work with are located in the UK. The workers we supply live in the UK.

Other relationships

As part of our business, we also work with the following organisation:

The Recruitment and Employment Confederation (www.rec.uk.com)

2: Our Policies

Summit Computer Recruitment Ltd t/a itecopeople has a modern slavery policy. In addition, itecopeople has the following policies which incorporate ethical standards for our staff.

2.1: Policy development and review

itecopeople’s policies are established by our directors, based on advice from HR professionals, industry best practice and legal advice, and in consultation with the REC. We review our policies on a regular basis, or as needed to adapt to changes.

3: Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.

After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.

Additionally, we have taken the following steps to minimise the possibility of any problems:

We require the businesses we work with to abide by our code of supplier conduct / address modern slavery concerns in their policies.
We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.

Our staff are encouraged to bring any concerns they have to the attention of management.

4: Our Performance

As part of monitoring the performance of itecopeople, we track the following general key performance indicators:

The level of training amongst our staff,
The speed with which we investigate related complaints, and the effectiveness of any whistle-blowing procedures, and/or
The level of compliance and transparency we have established in our supply chain.

Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of directors / the partners / our senior leadership team / briefly describe the staff:

the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
the effectiveness of enforcement against suppliers who breach policies
the amount of time spent on audits, re-audits, spot checks, and related due diligence
the level of modern slavery training and awareness amongst our staff

We benchmark our indicators against industry best-practice / carefully consider our indicators], in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk.

5: Our Training

All of our staff receive training and support that is appropriate to their role. In particular:

Our leadership team and/or senior supply chain managers receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.
All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this, our staff are encouraged to discuss any concerns that they have.

Training is refreshed regularly.