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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Project People Modern Slavery Statement

March 2021

1.        Introduction

  1. We take appropriate steps to ensure everyone who works for Project People has their fundamental human rights respected and anyone we do business with upholds these principles.
  2. This statement details policies, processes and actions we have taken to ensure that modern slavery and human trafficking do not take place in our supply chains or our business.
  3. It sets out the new and ongoing steps we are taking to address and prevent modern slavery taking place, both within our business and through our supply chains.
  4. Slavery is illegal everywhere in the world, but despite that, there are currently an estimated 40.3 million people in modern slavery or victims of human trafficking across the globe . Out of the millions of people trapped in modern slavery, 16 million people are exploited by the private sector, so it is paramount that businesses take action to end these abhorrent practices.
  5. At Project People, we are committed to playing our role in eradicating modern slavery in all its forms from our business and supply chain. We are taking the appropriate steps to ensure that everyone who works for Project People benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with also upholds these principles.

2.        Our Commitment

  1. The information in this statement details policies, processes and actions we have taken to ensure that slavery and human trafficking are not taking place in our supply chains or any part of our own business. It covers the activities of all businesses in all jurisdictions within the international Project People group of companies and is our Modern Slavery statement for the financial year ended 5th April 2022, required under the provisions of the Modern Slavery Act 2015 (the “Act”).

3.        Our Busness

  1. Project People’s purpose is to provide digital, global workforces, conducting our business to the highest possible ethical standards. We deliver innovative solutions – to simplify the links between businesses and individual contributors, teams and projects, partnering with clients to transform their businesses and services. We do complex and difficult things – so clients don’t have to.
  2. As part of Project People’s commitment, we will not tolerate any form of human rights abuse, including modern slavery or human trafficking, in any part of our business. Project People is committed to ensuring modern slavery plays no part in its business or supply chains. To satisfy this commitment, we undertake a range of different steps and continue to strive to achieve the highest legal, ethical, environmental and employee-related standards within our own business and supply chains, making sure that all stakeholders (including employees, partners and suppliers) are working together to eradicate modern slavery and human trafficking. In relation to our supply chain, we are focussed on working with long-term, strategic partners who demonstrate the same commitment to their people to ensure modern slavery plays no part in their or our business.

4.        Compliance Statement

  1. This Modern Slavery Statement complies with the Modern Slavery Act UK (2015)
  2. This Statement focuses on Project People’s compliance with the Modern Slavery Act UK 2015 and highlights the steps it takes to:
    1. Ensure there is no Modern Slavery occurring within our own business
    2. Provide assurance that Project People takes reasonable measures to mitigate the risk of Modern Slavery occurring within its supply chains
  3. This Statement is reviewed and signed-off annually by our CEO, Pank Koria, within 6 months of Project People’s financial year-end; in line with the legislative requirements set out in the Modern Slavery Act UK 2015.
  4. As an international business leader in recruitment and business process outsourcing, operating predominantly in the labour supply sector, Project People manages its business carefully and responsibly.
  5. Project People is committed to acting with integrity and treating all individuals with fairness and respect; this is demonstrated through the way it conducts its operations in accordance with set principles, procedures, and policies as well as having appropriate governance and controls in place.
  6. Project People was shaped and built on the values of being customer centric, curious, genuine, collaborative, engaging, and driven. These values have guided the way it does business, by driving our genuine beliefs of equality and fairness to reduce inequity, taking curious interest in the way our supply chain operates to give our customers the best experience, and collaborating together to share ideas and best practice.
  7. Project People’s Code of Conduct outlines these Corporate Values as well as the behaviours and actions that all personnel are expected to undertake and exemplify. The code is designed to provide a reference of standards in delivering services whilst ensuring compliance with applicable legislative and regulatory requirements.
  8. The Code of Conduct is the foundation upon which many of the Compliance policies and procedures are established. It is expected that all personnel are fully compliant with the Global Code of Conduct and Group policies and they are required to complete annual training to refresh awareness. Policies are maintained on the Group intranet and are accessible by all staff. The policies are reviewed on at least an annual basis, or upon a change in legislation.
  9. Partners and employees who raise concerns of slavery or human trafficking in good faith may do so without fear of discrimination or reprisal.

5.        Policies in Relation to Slavery and Human Trafficking

  1. In keeping with its commitment to ensure that personnel work with the highest standards of integrity and act authentically, several of Project People’s existing policies include commitments relating to the prevention of slavery or human trafficking in any part of the business or its supply chain.
  2. These include but are not limited to:
    1. Anti-Bribery and Corruption Policy
    2. Company Behaviour Policy
    3. Competition Policy
    4. Intellectual Property Policy
    5. Supplier Management Policy
  3. Channels are available for personnel or suppliers to confidentially raise any concerns regarding actual or suspected breaches to policy or behaviour that contravenes our Code of Conduct.
  4. Project People promotes the concept that compliance is everyone’s responsibility and take a zero-tolerance approach to any form of retaliation to individuals who raise concerns in good faith.
  5. In line with legal requirements, the Project People Financial Controller, Paul Deverson is responsible for presenting the annual Modern Slavery Statement for CEO approval.

6.        Supply Chain Due Diligence Processes

  1. The Procurement and Supply Management Policy is owned by the Chief Executive Officer, Pank Koria, with oversight delegated to the In-House Legal Counsel, Jacek Miotla.
  2. Project People’s Senior Leadership Team use a risk-based approach to monitor implementation of and adherence to the Procurement and Supply Management Policy and its application in the supply chain.
  3. Third Party risk and the associated mitigation plans is, as described above, monitored by the Senior Leadership Team on a regular basis.
  4. Suppliers are engaged on terms and conditions which are inclusive of requirements to comply with legislation such as the UK Modern Slavery Act 2015.
  5. Project People has the right to terminate any contract where there has been a breach of those terms or any other non-compliance with Project People policies.

7.        Risk Assessment, Prevention & Mitigation

  1. From a risk management perspective, Project People has identified areas to develop in conjunction with their supply chain, and a risk-based approach is under development.
  2. This approach is to include identifying and reviewing suppliers and vendors that fall within industries and/or countries that can carry higher risk, including in respect of modern day slavery and human trafficking.
  3. Project People is developing measures to assist in the review and management of these areas of risk, including an enhanced supplier and vendor take-on review and ongoing monitoring process, which is handled by the In-House Legal Counsel.
  4. Disciplinary and termination procedures are managed by the Senior Leadership Team to act should an individual or group of individuals breach any of our policies.

8.        Learning

  1. Project People wants to help its employees, partners, clients and suppliers to understand more about these issues and understand how to report any suspicions they may have related to modern slavery and human trafficking.
  2. The topic of Modern Slavery, and associated Anti-Slavery and Human Trafficking Project People Policies, continue to be flagged in induction training undertaken by new staff members starting with Project People. 
  3. Project People flags each update of this Statement and of the associated Anti-Slavery and Human Trafficking Policy to all staff members.
  4. It is also intended to further highlight the issue of Modern Slavery, as well as our Statement and Policy, to all staff members around (UK) Anti-Slavery Day (18th of October of each year).
  5. Project People continues to develop training on the issues of slavery and human trafficking and Project People’s Anti-Slavery and Human Trafficking Policy, to be delivered to relevant employees and partners on a targeted periodic basis.

9.        Looking Forward

  1. Project People will continue to develop and implement the measures mentioned above in respect of our supply chain.
  2. Project People’s approach to modern slavery and human trafficking risk will continue to evolve and we will continue to mitigate these risks through the provisions mentioned above during 2021 and beyond.
  3. Project People shall take responsibility for this statement and its objectives, and it will be reviewed and updated as appropriate.

10.     Summary

  1. Project People is fully supportive of the Modern Slavery Act and its aims and will not knowingly support or deal with any business involved in slavery or human trafficking. It will continue to invest in compliance with legal obligations.

Signed by:

CEO, Pank Koria

Date: 19th March 2021

In-House Counsel, Jacek Miotla

Date: 19th March 2021

Financial Controller, Paul Deverson

Date: 19th March 2021