SMART SOLUTIONS (RECRUITMENT) LIMITED modern slavery statement summary (2021)
Organisation address
Caerleon House,
Mamhilad Park Estate,
Pontypool,
Wales,
NP4 0XX
Mamhilad Park Estate,
Pontypool,
Wales,
NP4 0XX
We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.
This statement provides information for all 6 recommended areas
What is a modern slavery statement?
UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains.
Read more in the government guidance on publishing modern slavery statements.
Link to full statement
Go to full modern slavery statement on organisation’s website
PDF version of the statement (optional)
There is no PDF version of this statement.
PDF statements were first introduced to the registry for the 2023 statement year.
About this statement summary
All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.
Contents
- Legal requirement to publish
- Statement period and sign-off details
- Recommended areas covered by the statement
- The organisation’s sectors and turnover
- Number of years producing statements
- Policies
- Training
- Monitoring working conditions
- Modern slavery risks
- Finding indicators of modern slavery
- Demonstrating progress
Legal requirement to publish
SMART SOLUTIONS (RECRUITMENT) LIMITED has confirmed it is required to publish a 2021 statement by law.
Statement period and sign-off details
The statement covers the following period:
1 April 2020 to 31 March 2021
The statement was signed off by:
Robert Webb (CEO)
It was approved by the board (or equivalent management body) on:
1 April 2021
Recommended areas covered by the statement
Government guidance encourages organisations to cover a range of areas in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended areas in the statutory guidance.
We asked the organisation to tell us which areas its statement covers.
| Areas recommended by government guidance | Organisation’s response |
|---|---|
| The organisation’s structure, business and supply chains | Covered |
| Policies | Covered |
| Risk assessment | Covered |
| Due diligence (steps to address risk) | Covered |
| Training about modern slavery | Covered |
| Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time | Covered |
The organisation’s sectors and turnover
Sectors
The organisation operates in the following sectors:
- Public sector
- Automotive, machinery and heavy electrical equipment
- Cleaning and security services
- Construction, civil engineering and building products
- Consumer services, including accommodation, hospitality, tourism and leisure
- Cosmetics and toiletries
- Durable consumer goods, including electronics and appliances, home furnishings and other accessories
- Fashion, textiles, apparel and luxury goods
- Food and beverages, agriculture and fishing
- Forestry, timber products, paper and containers and packaging
- Healthcare and pharmaceuticals
- Information technology and telecommunication
- Mining, metals, chemicals and resources (including oil and gas)
- Professional and administrative services and supplies, including legal, consulting and accounting services
- Transportation, logistics, and storage
- Utilities: gas, water and electricity
- Waste management and recycling
Turnover
Its turnover in the financial accounting year of this statement was:
£100 million to £500 million
If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.
What does 'turnover' refer to in group statements?
If this is a group statement, this includes the total turnover for all the organisations covered by the statement.
Number of years producing statements
The organisation has been producing modern slavery statements for the following number of years:
More than 5 years
How does this work for group statements?
If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.
Policies (optional)
We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.
| Policy provisions we asked about | Organisation’s response |
|---|---|
| Freedom of workers to terminate employment | Included |
| Freedom of movement | Included |
| Freedom of association | Included |
| Prohibits any threat of violence, harassment and intimidation | Included |
| Prohibits the use of worker-paid recruitment fees | Included |
| Prohibits compulsory overtime | Included |
| Prohibits child labour | Included |
| Prohibits discrimination | Included |
| Prohibits confiscation of workers' original identification documents | Included |
| Provides access to remedy, compensation and justice for victims of modern slavery | Included |
| Other |
Not included
|
Training (optional)
We asked the organisation whether it provided training on modern slavery, and who it was for.
What counts as training?
We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks.
This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.
| We asked who the training was for | Organisation’s response |
|---|---|
| Your whole organisation | Yes |
| Your front line staff | No |
| Human resources | No |
| Executive-level staff | No |
| Procurement staff | No |
| Your suppliers | No |
| The wider community | No |
| Other |
No
|
Monitoring working conditions (optional)
Engaging with others
We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.
| We asked who the organisation engaged with | Organisation’s response |
|---|---|
| Your suppliers | No |
| Trade unions or worker representative groups | No |
| Civil society organisations | Yes |
| Professional auditors | Yes |
| Workers within your organisation | Yes |
| Workers within your supply chain | No |
| Central or local government | Yes |
| Law enforcement, such as police, GLAA and other local labour market inspectorates | Yes |
| Businesses in your industry or sector | Yes |
Social audits
We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.
What are social audits?
A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains.
By their nature, audits of supplier workplaces represent a snapshot in time.
| Social audits we asked about | Organisation’s response |
|---|---|
| Audit conducted by your staff | Yes |
| Third party audit arranged by your organisation | Yes |
| Audit conducted by your supplier’s staff | No |
| Third party audit arranged by your supplier | No |
| Announced audit | Yes |
| Unannounced audit | No |
Grievance mechanisms
We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.
| We asked if workers could raise concerns this way | Organisation’s response |
|---|---|
| Using anonymous whistleblowing services, such as a helpline or mobile phone app | Yes |
| Through trade unions or other worker representative groups | Yes |
Other ways of monitoring working conditions
We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:
Onsite surgeries/welfare interviews run internally and by civil society organisations (specialist charity partners)
Undercover task force
Automatic duplicate information reporting
Modern slavery risks (optional)
Warning
Identifying modern slavery risks is a vital step towards eradicating it.
The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.
We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.
Priority risks for this organisation (1 of 3)
Supply chain, particularly pertaining to PPE and second tier labour providers. Need to map suppliers and implement audit procedures. Supplier code of conduct not fit for purpose; revision underway.
| Questions we asked about this risk | Organisation’s response |
|---|---|
| Where it was most likely to occur |
Organisation’s response:
Within your supply chains.
|
| Who was it most likely to affect |
Organisation’s response:
|
| In which country | Organisation’s response: United Kingdom |
| Actions or plans to address this risk | Organisation’s response: Implementing a new supplier code of conduct. Implementing a new supplier audit procedure. Implementation of a multi-stage due diligence and compliance assessment process, which will cover both the procurement phase and the contract delivery phase. Reviewing current supplier listing. Conducting supplier mapping exercise. Seeking guidance and support from specialist provider in relation to supplier practice and human rights. |
Priority risks for this organisation (2 of 3)
Distribution sector; reputation for prevention practices well known in the waste sector. Identified that the distribution sector was a new focus for OCGs. Enhanced training delivered to those sectors.
| Questions we asked about this risk | Organisation’s response |
|---|---|
| Where it was most likely to occur | Organisation’s response: Within your own operations. |
| Who was it most likely to affect |
Organisation’s response:
|
| In which country | Organisation’s response: United Kingdom |
| Actions or plans to address this risk | Organisation’s response: Enhanced modern slavery prevention and detection training to be delivered to operations supporting the distribution sector. Continue to work with specialist groups ie. Slave Free Alliance and GLAA to obtain sector-specific data and intelligence. Education to clients within the sector. |
Priority risks for this organisation (3 of 3)
Covid-impact; moving the workforce from higher risk to lower risk georgraphical areas.
Labour market strain increases risk of on site teams being bribed to register potential victims.
Remote RTW.
| Questions we asked about this risk | Organisation’s response |
|---|---|
| Where it was most likely to occur | Organisation’s response: Within your own operations. |
| Who was it most likely to affect |
Organisation’s response:
|
| In which country | Organisation’s response: United Kingdom |
| Actions or plans to address this risk | Organisation’s response: Escalation procedures in place to report unusual activity e.g. moving of workforce or sudden departure of workers. Annual training delievered on both modern slavery and bribery. Auditing on new starters registered remotely to ensure adequate RTW documents obtained. Limitations on remote RTW checks carried out. Remote RTW checks now finished. |
Indicators of forced labour (optional)
We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.
What are ILO indicators of forced labour?
The International Labour Organization (ILO) has produced a list of the most common signs of forced labour.
They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’
More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour
| ILO indicators we asked about | Organisation’s response |
|---|---|
| Abuse of vulnerability | Yes |
| Deception | Yes |
| Restriction of movement | Yes |
| Isolation | Yes |
| Physical and sexual violence | Yes |
| Intimidation and threats | Yes |
| Retention of identity documents | Yes |
| Withholding of wages | Yes |
| Debt bondage | Yes |
| Abusive working and living conditions | Yes |
| Excessive overtime | Yes |
| Other |
-
|
Actions taken in response to finding ILO indicators
We asked the organisation to tell us whether its statement refers to any actions it took after finding indicators of forced labour
| Actions we asked about | Organisation’s response |
|---|---|
| Financial remediation, including repayment of recruitment fees | No |
| Change in policy | Yes |
| Change in training | Yes |
| Referring potential victims to government services | Yes |
| Supporting victims via NGO | Yes |
| Supporting investigations by relevant authorities | Yes |
| Other |
-
|
Demonstrating progress (optional)
We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks.
They provided the following answer:
October 2015 - partnered with UK Police foreces.
In 2016 we formed a corporate partnership with Hope for Justice.
2018 - became one of the first members of Slave Free Alliance. We work together to conduct on-site surgeries, welfare interviews, rescues and to provide a reliable National Referral Mechanism pathway. In 2018 we also began working with The Jericho Foundation to help reinforce our rehabilitation programme, relocating and placing victims of Modern Day Slavery back into work.