Recruitment Corporation we believe in the importance of equality in the
workplace. Being a responsible corporate citizen is not only the right
thing to do, it is good for the long term viability of our business. We
have an established Employee code of conduct which details the standards
by which we operate. We expect these same high standards from our suppliers.
We are committed to preventing acts of modern slavery and human trafficking
from occurring within our business and within the companies that we supply
permanent staff to.
We believe all staff have the same basic right to be treated with respect
and dignity at work as our own employees. We believe employment should
be chosen. There must be no forced, bonded or involuntary prison labour.
Employers must not be required to lodge monies or identity papers in order
to work and staff must be free to leave employment after the giving of
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 within the near future.
Jupiter Recruitment's Structure
Jupiter Recruitments parent company group is CS UK Recruitment Ltd.
The Group operates nationally within the United Kingdom.
We are a specialist recruitment company which is based in Birmingham from
our National Recruitment Centre.
Jupiter Recruitment Corporation focuses on permanent recruitment solutions
within the health and social care sector.
As a provider of recruitment services we do not have a particularly long
or complex supply chain. In the UK we work with a small range of suppliers
who provide goods and services across a number of different categories,
which focus around the health and social care sector. Therefore, we have
close relationships with our suppliers and good visibility of our supply
chain, and do not feel that it is particularly susceptible to labour exploitation
or other forms of slavery and human trafficking. Nevertheless, we are
committed to preventing these practices from occurring within both our
business and our supply chain, which is demonstrated by our policies and
due diligence procedures as outlined below.
Our Policy on Modern Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human
trafficking in our supply chain or in our business. Our UK suppliers are
required to comply with our Supplier Code of Conduct and Employee Code
of Conduct which reflects our commitment to acting ethically and with
integrity in our business relationships and to implementing and enforcing
effective systems and controls to ensure slavery and human trafficking
is not taking place in our supply chain.
Due Diligence Processes for Slavery and Human Trafficking
Our Own Business
As part of our own business we supply permanent personnel to a number
of clients. In this respect we have established and audited procedures
to ensure that those employees:-
• We ask if they have a right to work in the UK. This could involve
asking the individual direct to view their passport. A delay in providing
the passport might indicate a modern slavery issue;
employees, through the Employee Code of Conduct, are made aware of Jupiter
Recruitments requirement for employees to support and uphold human rights
principles and know that Jupiter Recruitment Corporation will not tolerate,
engage in or support the use of, forced labour.
Our Supply Chain
As part of our initiative to identify, monitor and reduce the risk of
slavery and human trafficking occurring within our supply chain, we have
undertaken the following due diligence procedures:-
(a) We have commenced the mapping of suppliers who provide goods and services
to our UK business to identify those suppliers whose goods or services
are heavily dependent on the provision of people;
(b) We have started to assess those suppliers in the UK supply chain who
we believe are in a high risk area, and have written to each such supplier
to note our commitment to transparency and combatting modern slavery within
our own organisation and our similar expectation from suppliers of goods
and services to us.
(c) We have reserved the right with our suppliers to request access to
their facilities for members of our Team to check compliance with our
Code of Conduct. Such on-site audits would also help us to identify whether
a supplier was engaged in unethical practices, which might include forced
labour or other forms of modern slavery.
Jupiter have helped staff find a permanent job with our clients we will
keep regular contact to ensure there are no slavery associated risk.
We will also follow this process with those further suppliers identified
as we complete our supplier mapping work, and with new suppliers. We will
include appropriate terms in our agreements which place an obligation
on suppliers to comply with the Modern Slavery Act 2015. 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
remedy such non-compliance and we would consider terminating our relationship
should we see no improvement in the way their business is conducted.
This approach is designed to:
• Identify and assess potential risk areas in our UK 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.
Risk and Compliance
Jupiter has evaluated the nature and extent of its exposure to the risk
of modern slavery occurring in its UK supply chain through its Internal
Audit Function in combination with the Group Procurement Team. As our
core business is focused on the provision of recruitment services in respect
of health care 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), we do not consider that we operate in a particularly high risk
sector. This evaluation process will continue on an annual basis.
Training and Performance Indicators
Given our view that Jupiter exposure to modern slavery risk is limited,
and the existing due diligence processes we already have in place as an
organisation, we have not implemented any specific training or key performance
indicators in relation to modern slavery and human trafficking.
Following a review of the effectiveness of the steps we have taken so
far this financial year to prevent modern slavery or human trafficking
occurring in our business and UK supply chain we intend to take the following
further steps to combat slavery and human trafficking during the course
of the 2018 financial year:
• To complete the mapping of our UK suppliers;
• Include appropriate anti-modern slavery terms in our agreements
• Continuing to raise awareness with our key teams provided through
training to ensure a high level of understanding of the risks of modern
slavery and so they are aware of what to look out for in respect of modern
• Maintain an open door policy with the Staff we have helped into
new job positions.
This statement is made pursuant to section 54(1) of the Modern Slavery
Act 2015 and constitutes our Group's slavery and human trafficking statement
for the current financial year