Pro-Force Limited 2020 Modern Slavery Statement - www.pro-force.co.uk
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Pro-Force Limited 2020
Modern Slavery Statement
www.pro-force.co.uk 1
1
INTRODUCTION
Modern
Slavery
Statement
“Our vision is to be recognised as one of the most trusted
labour providers to our clients, and as an employer of choice
to our workers. We understand that we have a duty to respect
the human rights of all individuals within our supply chain.
We are committed to tackling the exploitation of workers within our supply chain. Our goals are to work,
with other like-minded organisations, towards reducing and eliminating this threat in the UK.
This is our third statement regarding our efforts to prevent modern slavery in line with Section 54 of the
Modern Slavery Act 2015. It details our steps as taken during the year ending December 31st 2020 to
prevent modern slavery and human trafficking within our business operations and supply chain.”
Matthew Jarrett
CEO
Pro-Force Limited
2
INTRODUCTION
Pro-Force recognises that Modern Slavery, Human Trafficking and
Labour Exploitation are risks to our business and our supply chain.
Key Activities in 2020
Further investment into Evergreen
Training to allow us to provide a Development of the Seasonal
Further investment into our wider range of training courses, Worker’s Pilot including recruiting
accommodation bringing total including the development of from alternative countries such
bed space up to 5000 bespoke industry specific courses as Russia
Prioritising the development of Further expanding our client Continuing working with our
bricks and mortar housing, base with new partnerships in clients to improve pay rates and
including the purchase of an ex- different sectors working conditions
care home in Bognor Regis,
which houses 80 staff
About Pro-Force
Our commitment to improving worker welfare
standards and being seen as the Employer of
Choice for our staff is at the heart of what we do.
At a glance
£100m TURNOVER
32 O P E R AT I O N A L C E N T R E S
12,000 S TA F F O N A S S I G N M E N T
5,000 A C C O M M O D AT E D S TA F F
3
M O D E R N S L AV E RY S TAT E M E N T
Our Statement
This is our third statement regarding our efforts to preventing modern slavery in line with section 54 of
the Modern Slavery Act 2015. It details our steps as taken during the year ending 31st December 2020
to prevent modern slavery and human trafficking within our business operations and supply chain.
This statement has been approved by Pro-Force Limited board and senior management team.
Our Supply Chain
We are committed to ensuring transparency at all levels of our supply chain, from recruitment through
to placement with our clients. Our unique approach to conducting all recruitment directly and not
engaging third party agents at any stage places us in a position whereby we can be truly engaged with
our workforce and mitigate the risks to them during their recruitment process.
Our Commitments
Our publicly available policies outline our commitments to ensuring that business operations reflects
the latest in best practice. Our policies are owned by senior management and each of our procedures
is firmly imbedded into the business at all levels through our training programmes, ensuring each
member of the Pro-Force team acts in line with our own standards. Through regular assessment
against our own internal Quality Standard, we regularly review our procedures against our KPI’s to
ensure we are meeting, and even exceeding, our standards.
4
DUE DILIGENCE
Our Policies
Our Preventing Modern Slavery Policy is the key document that outlines what we do, and how we
do it. Its purpose is to minimise the risk of exploitation in our business, and define how we react when
it is discovered.
We require our clients to actively demonstrate commitment to our policies prior to working with them.
All our clients are required to undergo an assessment on their performance in key risk areas such as
health, safety and welfare before placing workers on assignment with them. This is actively reassessed
on an ongoing basis to ensure they hold the same principles in their practices as we do.
Our Modern Slavery Policy is supported by the below policies which detail all our internal good practices
and procedures to recognise and prevent modern slavery and labour exploitation within our supply chain:
Safe Recruitment Policy Anti-Bribery Policy
Ethical Trading Policy Complaints Policy
Our policies and our internal Quality Standard are based on the following commitments:
UN Guiding Principles on Retailer Codes of Practices
Business and Human Rights
GLAA Licencing Standards ETI Base Code
Our contractual terms with all our clients include clauses on compliance with the Modern Slavery Act
and related legislation. All our clients are required to actively demonstrate compliance and keep us
alert to any developments, or breaches.
Our Staff Handbook also highlights our values and the rights of every employee. We aim to be the
Employer of Choice for our staff and our workers, and create a workplace where each individual feels
valued, has the opportunity to develop, and enjoys their work.
55DUE DILIGENCE
Assessment of Risk
There are a number of challenges to identifying risk in our supply chain
and taking the appropriate action to reduce those risks. Summarised
below are the key risks we have identified and an overview of our action
to reduce them.
Lack of awareness
Throughout every stage of our relationship with each worker, from start of employment to the end, our
commitment is to ensure the health, safety and wellbeing of that individual. Our training processes
ensure each and every one of our staff members are equipped with the skills they need to conduct the
correct checks at each stage of the working lifecycle.
Through basic checks like robust interviewing procedures and our bespoke PAO (pre-assignment
orientation) training, we ensure that we are matching the right individual to the right role, as well as
ensuring they understand their own rights, which is a key aspect in the fight against exploitation.
A worker’s understanding and knowledge of their own rights, from rights to their own documents,
correct pay and ensuring they understand they do not have to pay to obtain work, is one of the most
crucial elements to prevent modern slavery.
This approach to increasing awareness carries on throughout a worker’s time with us. We conduct regular
refresher training sessions on key issues, including labour exploitation and employment rights, to ensure all
workers are informed, as well as conducting regular surveys to assess knowledge and ensure best practice
is embedded through every level of the organisation.
6DUE DILIGENCE
Recruitment Fees
One of the biggest risks in recruitment is the payment of illegal work finding fees or additional service
fees. We have made the biggest step we can in terms of reducing this risk to our staff by bringing the
entirety of our recruitment process in house.
Through reducing the use of third party agencies, we can reduce the risk of persons outside of Pro-
Force, but within the supply chain, charging use of illegal fees.
In order to be able to effectively conduct recruitment directly, we have established offices based in
Romania and Ukraine, as well as operational hubs in other countries such as Bulgaria. This ensures
that our own trained staff are on the ground conducting our recruitment, adhering to our own internal
standards. The client makes full payment for the recruitment services, and there is no requirement to
charge any form of "optional service" charge, as we offer the benefits of these services, such as
pastoral care, absolutely free to the worker.
Knowledge
We are committed to constantly improving our internal procedures to ensure worker protection, so are
continually reviewing our processes to ensure effectiveness. We do this through internal and external
training programmes to improve our own understanding.
Each of our managers and supervisors has undergone external “Stronger Together” training, and we
have been a Stronger Together Business Partner since 2015. Our Managing Director sits on the
Member’s Council for the Association of Labour Providers, and our Compliance Manager sits on the
GLAA Liaison Group. This ensures we have ready access to the latest thoughts, practices and risks
surrounding the prevention of labour exploitation and modern slavery.
7REDUCING HARM
2020 and Coronavirus
Due to the coronavirus outbreak in early 2020, we have had to amend some of our existing procedures
in order to be able to continue recruiting the correct quantity and calibre of staff for our clients.
Feed the Nation
Our Feed the Nation campaign focused on local recruitment for our clients, which carried new risks,
including:
Use of personal transport, risks of lack of insurance / tax etc.
Cultural differences could lead to conflict or exploitation
We have had to amend our procedures to consider cultural differences between staff to ensure
exploitation risks are managed, as well as increasing our checks on personal transport to ensure
that workers are safe when travelling to and from work.
Use of Third Parties
We have had to utilise the services of third party agencies during our Feed the Nation campaign in order
to access staff who are otherwise out of work in industries such as hospitality. This includes the use of
overseas agencies due to the global restrictions on travel. We have also done this through the temporary
GLAA licencing route, and worked on an introductory fee or fee sharing model, where the staff are engaged
and paid by Pro-Force, and not the agency. This has reduced the risk to staff through the involvement
of agencies.
Increased the frequency of regular exploitation checks and questionnaires to staff from third party agencies
Increased information available to staff to ensure they understand procedures and improve their
knowledge of modern slavery risks
We recognise that using third party agencies has an increased risk however through our improved and
enhanced procedures it allows us to mitigate this risk to an acceptable level and allows us to access
workers from other sectors who are looking for work due to the coronavirus. Our preferred method still
remains to do our recruitment directly ourselves, and we will use that method for preference.
8REDUCING HARM
Mitigation
The main area of risk internally is identified as our supply chain.
Source countries: Romania and Bulgaria both are listed in the Trafficking in Persons Report 2019,
and pose a risk of exploitation generally
Recruitment Methods: The use of third parties is open to exploitation
Lack of knowledge: Limited awareness of staff holding front line roles provides an opportunity for
criminals and exploiters to gain access to our supply chain
Tackling Risk
We strive to continue to be a leader in tackling and mitigating the risks of
modern slavery and labour exploitation.
Our strategies this year and going forward enable us to recognise and combat, head on, the risks in
our supply chain and industry.
Risk based approach to ongoing assessment and review of our procedures
Hands on, direct recruitment by our trained staff only
Only utilising third parties following completion of successful audit, risk reduction review and sign off
by a Director
Increasing the knowledge and awareness of our staff through bespoke training programmes
Incorporating the latest in best practice
Working with key stakeholders in industry groups and associations
9DUE DILIGENCE
Making a Difference
2020 has seen a number of instances of potential labour exploitation that
we have unearthed in our business.
We require our clients to actively demonstrate commitment to our policies prior to working with them.
All our clients are required to undergo an assessment on their performance in key risk areas such as
health, safety and welfare before placing workers on assignment with them. This is actively reassessed
on an ongoing basis to ensure they hold the same principles in their practices as we do.
Our Modern Slavery Policy is supported by the below policies which detail all our internal good
practices and procedures to recognise and prevent modern slavery and labour exploitation within our
supply chain:
Working with the GLAA regarding an ongoing investigation into a business in Bristol that was
actively exploiting staff, via some arrivals who found out about Pro-Force online, escaped from
Bristol and arrived on our doorstop
Discovery of recruitment fees paid to agencies overseas outside of our supply chain prior to
working for Pro-Force, investigated and escalated up to the GLAA
Allegations of fees paid for work, including completing investigation with clients and escalating up to
the GLAA
Our ability to recognise and suitably deal with, prioritising worker safety at all stages, allegations of
exploitation within ours and our client's businesses improves year on year. We are confident that we
have the skills in house to allow us to suitably investigate allegations, provide support where required,
ensure worker welfare and assist the relevant authorities in their investigations.
10MEASURING OUR ACHIEVEMENTS
Next steps
Our programme for next year includes the following steps:
Development and implementation of new industry specific CPD apprenticeship programme,
1 providing knowledge and formal qualifications for our staff
Engage at different levels with the correct stakeholders to gain new skills and knowledge to
2 improve our practices
3 Update our internal procedures and tools as new information becomes available
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11M O D E R N S L AV E RY S TAT E M E N T
Aims
To embed Pro-Force values and policy at all stages of our business
To develop a robust framework through our Quality Standard and Policies of risk assessment,
mitigation and review to identify and maintain best practice
Provide our staff and workers with the skills they need to recognise and tackle modern slavery,
prioritising their health, safety and welfare at all stages
Key Performance
Indicators
100% awareness and completed training programmes on modern slavery risks
Improvement on scoring and achievement against our Quality Standard in all internal audits
Improvement of attraction and retention rates
Worker interview and survey results and action taken to improve standards
Full action plans for each area of the business to improve our standards
12M O D E R N S L AV E RY S TAT E M E N T
Training
All of our colleagues need to be engaged to help us in the fight against modern slavery and human
trafficking. It’s crucial that all our staff know how to recognise the signs of exploitation, and what to do if
they discover them. It’s about making sure our values resonate at every level of the business, rather than
have a small group of experts in place to try and cover the wide scope of the business. Through our
training programmes, we ensure that all colleagues at every level hold the skills they need.
Our core training programmes have modern slavery prevention considerations built into every aspect,
from recruitment and sourcing through to worker management.
Our training company Evergreen Training has been developed to ensure we are able to offer our internal staff,
our workers, and our clients, the very best in bespoke learning and development programmes.
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13M O D E R N S L AV E RY S TAT E M E N T
Continuous Improvement
It’s not just the here and now that’s crucial for success, it’s what we are doing tomorrow, and in the
future. Our next steps for developing our training include:
Development of e-learning modules for Increasing external training provided by
our workers and our staff industry experts
Engaging key external stakeholders to Improving our training facility by
widen the scope of our training provision expanding what we can offer our clients
as well as our staff through our training
company Evergreen
Collaboration
Gangmaster’s and Labour Abuse Authority
As a licenced labour provider since 2005, Pro-Force works collaboratively with the GLAA to ensure we
are always up to date on the latest in risk management and mitigation in our business.
Fresh Produce Consortium
As a crucial part of the Working Group, Pro-Force helped shape the latest in guidance for seasonal
accommodation and sit at the forefront.
SEDEX
As a registered member of SEDEX, Pro-Force incorporate the principles of the ETI Base Code into all
aspects of our business practices.
Stronger Together
A Stronger Together Business Partner since it’s inception in 2015, we ensure our internal procedures reflect
the latest in pragmatic approaches to tackling and preventing modern slavery within our supply chain.
Clearview
As pilot operators of the new Clearview Accreditation scheme, Pro-Force has incorporated the standards
into our own Quality Standard, against which we assess our performance.
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14Pro-Force Limited
Modern Slavery Statement
Pro-Force Limited 01227 733880
Hunstead House enquiries@pro-force.co.uk
Chartham, Kent www.pro-force.co.uk
CT4 7PE
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