Modern Slavery and Human Trafficking Statement

Introduction

Boost Pay Limited opposes any form of worker exploitation and is committed to ensuring that modern slavery and human trafficking do not exist in our business or in the wider business environment of our supply chain. This statement is made in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. Eileen Breeze, Managing Director, has overall responsibility for implementing and reviewing this statement, as well as monitoring the use and effectiveness of its content and proposals to eradicate modern slavery and human trafficking in Boost’s supply chain.

Business

Boost is a contracting intermediary company which operates in the temporary labour market in the UK. The company employs 15 internal employees who work in our head office in Walberton. Boost supply temporary labour, engaged as employees, subcontractors and limited company contractors, to a variety of sectors including construction, media and commercial. The following is a non-exhaustive list of policies and documentation that assist Boost with our approach to prevent modern slavery and human trafficking in our operations;

  • Whistleblowing policy – our whistleblowing policy provides a mechanism for our employees to report concerns within Boost
  • Anti-slavery policy – our anti-slavery policy demonstrates Boost’s commitment to preventing slavery and human trafficking and sets out the steps in place with the aim of ensuring there is no worker exploitation in Boost’s own business and supply chains. It educates our employees on the action to take if they believe or suspect that there has been a breach of the policy
  • Equal opportunities policy – our equal opportunities policy reflects our commitment to acting ethically and with integrity in all our business relationships
  • Verification of identity and right to work – we undertake Right to Work checks on our employees in line with the Home Office requirements

  • Supply Chains

    Our business partners include, but are not limited to, our clients and subcontractors. Our business relationships are governed by written terms and contracts. We expect our business partners to promote the same standards within their own company. Boost will never, knowingly, enter into a business relationship with any organisation involved in modern slavery or human trafficking.
    As a contracting intermediary, the key areas of our operation that could be affected by modern slavery and human trafficking are our directly hired employees and subcontractors. Forced labour, servitude and trafficking of labour are key areas of consideration for us.
    Our employees and those we work with are encouraged to challenge any unethical, dishonest or unacceptable behavior. All concerns raised will be treated seriously and will be investigated with the relevant parties, without bias and with absolute discretion. Appropriate action will be taken by the relevant party as required.

    Due Diligence Process

    During the last year we have rolled out a new internal staff training programme on due diligence procedures which will assist in identifying a case of modern slavery as detailed below. Boost check the right to work documentation of employees to confirm legitimacy of their right to work in the UK. Relevant documents are inspected and photocopied and records are kept in line with the UK Home Office guidance. When appropriate, Boost’s internal employees will notify Immigration Enforcement of any issues with right to work documentation. In event that an employee or subcontractor chooses to have their remuneration paid into a third-party account, we obtain written permission from both the employee/subcontractor and the account holder before making payment into the bank account. We also obtain ID from both parties. Limited company contractors must be paid through a limited company bank account. We undertake due diligence on all limited company contractors via a prescribed checklist drafted specifically for the engagement of limited company contractors. On an ongoing basis, responsibility lies with the Managing Director to ensure that our processes, training and our understanding of the issues involved in modern slavery are kept up to date.

    Next Steps

    We understand that the risk of modern slavery is ongoing and so, we must continue to improve our processes in the years ahead, with particular focus on;
  • Ongoing training initiatives on modern slavery including, but not limited to, how to identify the signs that a worker is potentially being exploited and what process to follow if potential issues surrounding modern slavery are identified. We will repeat this training annually and update it as necessary
  • Include modern slavery training as part of the internal induction process

  • We will be working with advisors from Aspire Business Partnership who have been awarded with a Certificate in Investigating Modern Slavery by the Gangmasters Licensing Authority, in partnership with the University of Derby. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

    Eileen Breeze
    Managing Director

    Date: 01/12/2018


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