MODERN SLAVERY POLICY

POLICY

Published in accordance with the Modern Slavery Act 2015, this statement outlines the steps taken by Keystream Group to prevent modern slavery and human trafficking throughout our supply chains or in any part of our business.

KEYSTREAM GROUP’S STRUCTURE

Keystream was established in 2011 by Andrew Jukes and Johnny Stein.

Operating solely in the UK, Keystream provides non-clinical Healthcare, Charity and Government organisations recruitment services to the public and private sector across both contract and permanent vacancies. The types of roles include but not limited to IT, Procurement, Marketing and Commissioning. .

We employ approximately 45 people at our offices in London (Head office) and Newcastle.

All the hirers we work with, and the work-seekers we provide, are known to and identified by our employees.  Some of these work-seekers operate through their own limited companies.

The company operates an accredited ISO Quality Management System, with integrated policies, processes and for all business activities and operations.

Keystream Group is a subsidiary of Keystream Human Capital Limited, a UK-headquartered group of companies. The group’s total annual turnover exceeds £36 million, bringing it within the scope of Section 54 of the Modern Slavery Act 2015. This statement is published solely on behalf of Keystream Group.

 

KEYSTREAM GROUP’S CURRENT POSITION

• Keystream Group takes its responsibility for ensuring the risk of modern slavery and human trafficking is minimised across its supply chain seriously.
• Our supply chain is minimal and solely relates to the operation of the business and services to our clients and contractors.
• We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business.
• Keystream Group solely operate in the UK, as such we believe we operate in a “low risk” location for Modern Slavery.
• We ensure strict compliance checks are carried out for all workers supplied or managed by us. We verify the identity of each temporary worker, verify the worker’s right to work, obtain proof of address and ensure this matches the name and address of their bank account.
• To ensure our suppliers are compliant, we have an umbrella company PSL which we regularly review and audit before recommending to our candidates.
• We reserve the right to conduct spot-checks of the businesses who supply us, to investigate any complaints.
• We have a long standing relationship with the majority of our supply chain. We continue to see and speak to our main suppliers regularly to maintain and grow these relationships. We undertake due diligence when considering taking on new suppliers and regularly review our existing suppliers.
• We are active members of our UK trade body – Recruitment & Employment Confederation (REC) and ensure all our policies and procedures meet or exceed their membership requirements.
• We recognise knowledge is key and all employees must complete our mandatory Modern Slavery training and actively encourage employees to report any suspicious activity.

Keystream Group have a whistleblowing policy in place intended to provide a process for and protection to employees and candidates who wish to raise genuine concerns regarding, amongst other things, our business practices. Keystream Group expects its employees to report concerns of non-compliance, no matter how trivial, in line with the established policies and procedures.

While we believe we are in a low risk environment, during 2023 we will implement further training to ensure employees are fully aware of the Modern Slavery Act 2015 and both their personal and the organisation’s responsibilities under the act. This training will include:

• 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 messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.

Our policy (below) reflects our commitment to act with integrity and ethically in all our business relationships and to implement and enforce effective systems and controls, including in relation to combatting modern slavery and human trafficking in our supply chains.

This policy is updated each year to ensure it is consistent with recent legal developments and recommended good practice as well as making express reference to modern slavery in a supply chain as an example of a potential concern employees might disclose under the policy.

• Modern slavery is a crime and a violation of fundamental human rights. It 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 to exploit them for personal or commercial gain.
• Keystream Group has a zero-tolerance policy to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We have implemented and effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains
• Keystream Group is also committed to ensuring transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from our Contractors, Suppliers and other Business Partners.
• This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, contractors, external consultants, third-party representatives and business partners.
• This policy does not form part of any employee's contract of employment and we may amend it at any time.

 

RESPONSIBILITY FOR THE POLICY 

2.1 The Management Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations.

2.2 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

 

COMPLIANCE WITH THIS POLICY 

3.1 You must ensure you read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify your Manager as soon as possible if you believe or suspect a conflict with this policy has occurred, or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery at the earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. The matter will be referred to the People team and be dealt with in conjunction with the necessary agencies or third parties.

3.6 We encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith, their knowledge or suspicion that modern slavery is taking place in any part of our business or in any of our supply chains.

 

COMMUNICATION AND AWARENESS OF THIS POLICY

4.1 Training on this policy, and the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

4.2 Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

 

MEASURING EFFECTIVNESS

5.1 Keystream Group uses the following key performance indicators (KPIs) to assess the effectiveness of our efforts to prevent modern slavery and human trafficking in our business and supply chains:

• 100% of staff complete Modern Slavery training within 30 days of joining.
• Annual refresher training delivered to all employees.
• 100% of work-seekers are subject to full identity, right-to-work, and address verification checks
• All umbrella companies on our Preferred Supplier List (PSL) are reviewed at least once per year.
• At least three supplier spot-checks are conducted annually.
• No modern slavery-related reports or complaints have been received during the reporting period.
• This policy and statement are reviewed and updated annually by the Management Board.

 

BREACHES OF THIS POLICY

6.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

6.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.