Modern Slavery is a term used to encapsulate two offences in the Modern Slavery Act 2015:
We have a responsibility to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety, human rights laws and international standards are adhered to, including freedom of movement and communications. We are committed to improving our practices to combat slavery and human trafficking.
Millbank Holdings Limited and its subsidiaries (Millbank) is a resource management and recruitment specialist business. We provide services to clients across a number of sectors.
Our subsidiaries are:
We have an Anti-Slavery Policy that together with our Code of Conduct and business ethics policy, ensures that our staff are in adherence with the requirements of the Modern Slavery Act 2015.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains. All our suppliers as part of the procurement process confirm that they are in adherence with the Modern Slavery Act 2015.
We procure in the following areas:
A review of the risk of potential slavery and human trafficking has been undertaken and the business has identified the following areas that pose the most significant potential risk:
The potential risk - enslaved or human trafficked individuals are placed in work as agency labour with clients.
Risk control – Millbank undertakes rigorous checks on each individual including; eligibility to work, reference checking, qualifications, proof of national insurance, and bank details to ensure each person is acting in their own right. Millbank informs all of their clients that they adhere to the conditions set out in the Modern Slavery Act 2015.
The potential risk - the use of suppliers that contravene the Modern Slavery Act 2015
Risk control - all suppliers whom set up a supplier account with us; are required to complete and return an Approved Suppliers Questionnaire (MH43) and as part of this they must commit to their adherence to the requirements set out in the Modern Slavery Act 2015.
As part of our initiative to identify and mitigate risk we carry out the following:
To measure how effective our risk control measures and due diligence is to ensure that slavery and human trafficking is not taking place in our business or supply chains, we have implemented Key Performance Indicators (KPIs) to ensure;