This statement sets out Sopra Steria Recruitment’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to the financial year ending 31st December 2016.
As part of the Recruitment profession, Sopra Steria Recruitment recognises that it has a responsibility to take a robust approach to prevent slavery and human trafficking.
Sopra Steria Recruitment is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of Sopra Steria Recruitment Limited. Sopra Steria Recruitment is based in Reading, Manchester, Edinburgh and Hemel Hempstead in the United Kingdom.
Formed in 1979, Sopra Steria Recruitment is a wholly-owned company within the Sopra Steria Group; a European leader in digital transformation
Sopra Steria Recruitment delivers recruitment services which help organisations in the public and private sectors attract people, knowledge and skills to enable business performance and accelerate change. We provide a breadth of solutions, tailored to our clients’ specific needs, in permanent, contract, interim and managed recruitment, capable of providing people across all technical and business disciplines.
Sopra Steria Recruitment also provides recruitment services to Sopra Steria Limited, and its joint ventures NHS SBS and SSCL.
Sopra Steria Recruitment is committed to minimising its impact on the environment and is certified to the ISO 14001 standard. We deliver through world-class recruitment workflow and compliance processes, certified to the ISO 9001 standard and aligned to all relevant employment and recruitment legislation. We are long-term members and twice award winners of the Association of Professional Staffing Companies, providing clients with an assurance of the highest quality delivery.
Our Supply Chains are primarily comprised of organisations within the UK. Sopra Steria Recruitment avoids contracting with suppliers or sub-contractors which are located within geographical areas where slavery and human trafficking are a higher risk. However, we recognise that our upstream supply chain does include countries with a higher risk of modern slavery or human trafficking and we expect our suppliers to pass on this obligation to their supply chain in higher risk countries. We also recognise that slavery and human trafficking does occur in the UK and Europe.
Sopra Steria Recruitment’s approach to preventing slavery and human trafficking
Sopra Steria Recruitment has implemented the following policies that describe the steps the Company takes which prevent slavery and human trafficking in its operations and supply chain:
- Code of Ethics – applicable to all Sopra Steria Recruitment and Sopra Steria employees including in India, the Code of Ethics describes our commitment to the 10 principles of the UN Global Compact, including fighting against child labour and exploitation, forced labour or any form of compulsory labour.
- Sustainability Policy – applicable to all Sopra Steria Recruitment employees, this policy commits the Company to preventing slavery explicitly. It also requires us to uphold human and labour rights.
- Business Integrity Policy – it is important to Sopra Steria Recruitment that any fraud, misconduct or wrongdoing by workers or officers of the Company which would threaten the integrity of the business, including any circumstances that may give rise to an enhanced risk of slavery or human trafficking, is reported and properly dealt with. The Company encourages all individuals to raise any concerns that they may have about the conduct of others in their business dealings on behalf of the Company or about the way in which the business is run using the procedures outlined in this policy.
- Sustainable Procurement Policy – this policy applies to all procurement activity in the UK and requires Sopra Steria Recruitment to adhere to social and ethical standards, and human and labour standards in the procurement of goods and services. Our standard terms and conditions for suppliers also require suppliers to uphold human and labour rights and (in the UK) to prevent modern slavery and human trafficking in their own operations and supply chains.
- Policy for Recruitment/Engaging workers – Sopra Steria Recruitment uses only specified, reputable employment agencies to source labour where required and always verifies the practices of any new agency it is using before accepting workers from that agency. In the UK, a requirement to comply with the Modern Slavery Act 2015 will be contained in our updated Agency contracts and existing suppliers will be required to comply on renewal.
- Policy for Engaging Workers – In the UK, a statement of our compliance to the Modern Slavery Act 2015 will be updated in our standard contractor contract.
Processes and practices
Within our own operations
The prevention of modern slavery and promotion of human rights is largely achieved by adherence with relevant employment legislation. Sopra Steria Recruitment has a responsibility to ensure that our employees are not being exploited, that they are safe at work and that relevant employment, health and safety and human rights laws are adhered to. A suspected case of slavery or human trafficking within the Company’s own operations should be raised using the procedures outlined in the Business Integrity Policy.
Due Diligence: The following steps are undertaken to ensure there is no slavery or human trafficking within our own operations:
- All employees have a contract of employment that sets out the rights and obligations arising from their employment, including the notice period needed for them to terminate the contract and leave the Company’s employment. Employees are free to serve notice at any time.
- The Company carries out verification of an employee’s identity and ongoing right to work in the UK and does not seek to withhold any of an employee’s identity documents or passport etc.
- All employees are paid at least the national minimum wage and the Company adheres to all legislation in respect of working time and statutory time off, providing for minimum amounts of holiday, time off due to personal emergencies, sickness and maternity/paternity and minimum rest breaks and periods.
Within our supply chain
Our Sustainability Risk Matrix for supply chain management determines levels of risk in supply categories. If a category of supply has been assessed to have a higher level of risk, suppliers within that category with which Sopra Steria Recruitment maintains a certain level of spend will be invited to participate in our supplier engagement process for sustainability, which includes a more thorough assessment of suppliers’ sustainability management processes, including the prevention of slavery and human trafficking.
Sopra Steria Recruitment utilises the services of Sopra Steria India employees. Indian Companies are prohibited from employing any bonded or child labour. The Constitution of India guarantees the right to life and liberty and prohibits the practice of debt bondage and other forms of slavery both modern and ancient. Human trafficking in any form is prohibited and any contravention of this provision is an offence punishable in accordance with the law. All Sopra Steria India employees are paid at least the Minimum Wage as prescribed and amended by the local legislation from time-to-time. Sopra Steria India complies with all the applicable local labour laws.
Sopra Steria Recruitment undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our due diligence and reviews include:
- Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
- Using the Company’s Sustainability Risk Matrix, which covers more than a dozen key sustainability risk areas including procurement, and which was introduced in late 2016. Suppliers that have an overall higher sustainability risk score will be asked about the steps they are taking to prevent human and labour rights abuses.
- Evaluating the modern slavery and human trafficking risks of each new supplier by using a new supplier questionnaire and our Sustainability Risk Matrix Assessment process.
- Requiring all suppliers to abide by our Supplier Code of Conduct, which prohibits human trafficking and slavery, and requires suppliers to take proactive steps to ensure it does not occur in their operations of supply chains
- Taking steps to improve substandard suppliers' practices, including providing advice and guidance to suppliers requiring them to implement action plans;
Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our terms and conditions, including the termination of the business relationships or contracts.
As experts in the supply of agency labour, we are committed to respecting international human rights and fair labour practices. Where we engage Contractors through their Personal Service Companies (where they are most often employed as the sole employee) we conduct rigorous pre-placement compliance checks including eligibility to work, references, qualifications and proof of national insurance numbers. Where we engage via Agencies, a requirement to comply with the Modern Slavery Act 2015 will be contained in our updated Agency contracts and existing suppliers will be required to comply on renewal.
Training and awareness-building
Sopra Steria Recruitment will undertake an awareness-building communications campaign to enable all employees to understand that slavery and human trafficking is a persistent problem, the risks and signs of slavery and human trafficking, and the requirements of the Modern Slavery Act. The campaign will first seek to raise awareness amongst people managers and remind them of their responsibility to ensure their team members are aware. Special, more detailed briefings have been and will also be carried out in particular functional areas of our business where employees may have additional opportunity or responsibility to identify slavery and trafficking risks, such as HR, Legal and Procurement.
Sopra Steria Recruitment has established the following key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. These indicators effectively establish the activities the Company plans to carry out. The indicators and activities will be reviewed at least annually.
- Incorporate requirements for suppliers to work to prevent slavery and human trafficking into our standard terms and conditions for suppliers
- Implement a procurement risk matrix and assessment process that includes slavery and human trafficking, in order to assess the risk areas of our supply base on an ongoing basis
- Integrate the topic of slavery and trafficking into our supplier engagement processes for sustainability
- Execute an awareness-building communications campaign on slavery and human trafficking, and the requirements of the Modern Slavery Act
Responsibility for Sopra Steria Recruitment’s anti-slavery initiatives is as follows.
Responsibility for policies related to anti-slavery is allocated across the following areas:
- Human Resources – Sopra Steria Director of Human Resources, for policies related to the prevention of slavery and human trafficking in our own operations, and for the Sustainability Risk Policy
- Sopra Steria Group SA (France) President, for the Sopra Steria Group Code of Ethics
- Procurement – Sopra Steria Chief Procurement Officer, for policies related to the prevention of slavery and human trafficking in our supply chain.
- Managing Director – Sopra Steria Recruitment for policies related to the operation of the business
The Head of HR Services in Human Resources is responsible for defining and carrying out risk assessments for employment within our own operations, as appropriate.
Our Sustainable Procurement Lead and other members of our Sustainability team develop risk assessments as part of our Sustainable Supply Chain Management programme.
In our own operations: The due diligence carried out to ensure the Company complies with all employment law is the responsibility of various members of the Human Resources team in the variety of checks undertaken during different stages of employment, from initial recruitment onward.
In our procurement and supply chain management activities: The Company’s procurement management team have responsibility for undertaking due diligence activities, and for such activities related to slavery and human trafficking and take input from other parts of our business, including Legal, HR and Sustainability.
Training and awareness-building
Ensuring Sopra Steria Recruitment’s employees are aware of the risks and signs of slavery and human trafficking, and the Company’s responsibilities under the Modern Slavery Act is the responsibility of all managers.
This statement has been approved by Sopra Steria Recruitment’s board of directors in relation to the Financial Year ending on 31st December 2016.
Policy signed by Peter Cashmore, Company Secretary, 11 July 2017