Foreword
Throughout this last year, it has continued to be a priority for nGAGE Specialist Recruitment Limited (“nGAGE”), together with each of our group companies, to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our organisation and supply chain. The Group acknowledges its significant position in the international recruitment market which necessitates that nGAGE be held to the highest ethical standards for the fair treatment of its workforce. Mandatory training exercises in Equality and Diversity in the Workplace and Modern Slavery regulations across all our operations and supply chains ensure that workers feel safe, comfortable and valued in their respective places of work.

In the recruitment industry, Modern Slavery can appear under many guises – most prevalently, but not exclusively, nGAGE is conscious of practices concerning forced labour, exploitative work conditions as well as debt bondage or human trafficking. Being a global leader in its industry, nGAGE takes the responsibility of sourcing and supplying staff very seriously and is mindful of the potential exploitation that can arise from working in such a personal industry that engages directly with people’s employment. We ensure such suitable processes and policies are in place that firstly, such occurrences can be avoided through vigilant screening processes, but also that we might take necessary action if required should instances of Modern Slavery be recognised.

Business Structure
nGAGE provides shared overhead and support services to our recruitment and managed service businesses who operate globally to become a leading player for specialist recruitment. It is also the parent company of a group that provides a variety of talent, bank and managed services across diverse sectors such as Built Environment, STEM, Health & Social Care, Public Sector & Not-for-Profit and Professional Services.

Headquartered in London, UK, we are proud to have a diverse and talented workforce comprising over 1,100 colleagues worldwide, employing teams based in the United States, South Africa, throughout Europe and Australia. We are supported in our work by our international shared services centre colleagues in India, Pakistan, South Africa and the Dominican Republic via trusted partners who share the high standards and requirements that the nGAGE Group demands.

Whilst international regulations and guidance aim to promote consistency worldwide in addressing modern slavery, nGAGE understands that the implementation of these measures remains subject to the individual capacities and priorities of each country; the Group is committed to its engagement with and verification of each candidate, client and supplier, both in the UK and abroad, to ensure they
meet to nGAGE’s requisite standards.

Worker Agreements

nGAGE ensures that all agreements are:

• detailed, accurate and comprehensible;
• tailored to each worker’s specific roles and responsibilities; and
• in a language where the information is accessible and understandable

All agreements are drafted to clearly explain that any worker, including migrant workers, may exercise a right to cancel their work contracts at any time with no financial penalty, subject to giving reasonable notice, in compliance with the local law or collective agreement. While we carry out “right to work” checks on all of our workers we will never retain the original documentation. Where required we engage in-country experts to ensure we are compliant with each of the labour laws and taxations systems applicable to a country that we work in. We have prohibited the use of labour brokers, including child labour, who do not comply with the local labour laws of the country in which recruiting occurs.

Supply Chains
We recognise our supply chains represent a high risk. We lend particular attention towards the management of labour in supply chains which involves the auditing of, and if required, subsequent investigation into, our suppliers to ensure that they are operating within the confines of the law and meet nGAGE’s own ethical standards.

It is expected that all suppliers to, and companies within, nGAGE Talent maintain the highest ethical quality in their commitment to combatting modern slavery. As part of a suppliers onboarding we will
ask them to signify their commitment by signing to our Supplier Code of Conduct.

Policies
Our established Anti-Slavery and Human Trafficking Policy serves as a central framework for our opposition to modern slavery and is supplemented by training, process and procedure. We continuously subject this policy to review and update in order to keep up to date with changes in legislation and to maintain the standards of equality and fairness that represent nGAGE.

nGAGE’s Code of Conduct sets out the behaviours that we expect from all of our colleagues in their business dealings. This code applies to all nGAGE colleagues internationally in our interactions with each other, candidates, customers, suppliers and agents and refers directly to the Modern Slavery Act 2015. By adhering to this code, nGAGE is able to foster a culture of respect, fairness and integrity throughout our organization.

Processes
We ensure all group companies comply with strict compliance checks for all workers supplied or managed by us to ensure adherence to high standards for all workers under our supervision. Before any worker is onboarded or placed, our teams adhere to a zero-tolerance stance through the verification of a worker’s identity and their Right to Work in accordance with the laws applicable in the jurisdiction they are in.

We do not withhold any worker identity or immigration documents for any purpose whatsoever and
this is embedded in our processes and procedures. Our central compliance function ensures compliance with this ensuring any potential issues are escalated before onboarding. We regularly complete due diligence on the umbrella companies, employers of records, professional employment organisations and similar in our supply chains. These due diligence checks and audits ensure we collaborate only with partners who align with nGAGE’s own compliance standards.

Training
We provide regular, mandatory training to our staff ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. As a part of our compliance training obligations, employees must complete training courses in Modern Slavery and Equality and Diversity in the Workplace, as well as other courses, all of which require an assessment with individual pass grades in order to complete the training.–

We mandate that our business partners and suppliers provide training to their own staff. To ensure a consistent level of training that mandate includes making available certain training modules directly available to a number of our key suppliers.

As part of our training nGAGE makes it clear that we all have a responsibility to help tackle these matters. We are clear that they should report any suspected incidence of modern slavery in the workplace and that the Modern Slavery Helpline is a resource they can, and should, use.

Further steps
Modern slavery has no place in any part of nGAGE. The Board fully supports eradicating slavery in any form from all areas within our supply chains and recognise that further steps should always be considered. nGAGE will continue to collaborate with government agencies and NGOs to encourage our continuous improvement and to demonstrate our commitment to combatting modern slavery in our operations. We intend to carry out a further review of our supply chain onboarding and audit
processes globally to ensure our suppliers continue to meet the standards that we expect.

Statement made following financial year ended April 2024
Group Chief Operating Officer
Adam Herron