Modern Slavery

OUR POLICY

ACS Recruitment Solutions Ltd is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.

‍

1. ACS Recruitment Solutions is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.

‍

2. ACS Recruitment Solutions provides appropriate training and awareness information for all of its staff in particular:

Our recruiters, HR personnel, and staff involved in our procurement and supply chains undertake training

courses that include guidance around modern slavery and human trafficking, as well as other wider human rights

issues.

All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

‍

3. Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to the ACS Recruitment Senior Management.

‍

4. Reporting & Definition of a Complaint. A complaint is defined as any report of actual or suspected violation against ACS’s Code of Conduct or policies, where the violation has an adverse human rights impact.

Complaints may come from employees, workers, suppliers, or third parties. Reports can be made confidentially to ACS Senior Management via established reporting channels.

‍

5. Reports surrounding these issues are taken extremely seriously by our board of directors, who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

Working with the appropriate organisations to improve standards, Passing details to appropriate law enforcement bodies.

‍

Our committed approach

· Victim-first approach: The safety, rights, and wellbeing of victims are prioritised above all else.

· No retaliation: Victims and whistle blowers will not face discrimination or retaliation.

· Confidentiality: All reports and investigations will be handled with sensitivity and discretion.

· Collaboration: ACS will work with trusted partners, NGOs, and authorities to provide remedies and support to victims.

· Continuous improvement: Lessons from remediation cases will feed back into policy, training, and risk assessment.

ACS does not meet the criteria required to publish a Modern Slavery Statement under Section 54 of the Modern Slavery Act 2015. However, we are voluntarily aligning with best practice and working towards our key performance indicators (KPIs) to strengthen protections across our operations and supply chains.

‍

6. We regularly monitor our risks in this area through the use of relevant key performance indicators, including:

· The percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements,

· The percentage of workers and/or candidates supplied from audits.

· The effectiveness of enforcement against suppliers who breach policies.

· The amount of time spent on audits, re-audits, spot checks, and related due diligence, and

· The level of modern slavery training and awareness amongst our staff.

‍

ACS Staffing Solutions Remediation Procedures include:

Step 1: Immediate Protection of the Victim

· Remove the victim from harmful conditions.

· Ensure access to urgent medical, psychological, or welfare support if required.

· Guarantee that no penalties or repercussions fall on the victim.

‍

Step 2: Initial Assessment

· Senior management assesses the seriousness of the complaint.

· Collect information and evidence while ensuring confidentiality and victim safety.

‍

Step 3: Investigation

· Conduct a prompt, fair, and transparent investigation.

· Where appropriate, involve external experts, NGOs, or law enforcement.

‍

Step 4: Remedy & Support Depending on the case, remedies may include:

· counselling, or healthcare for victims,

· Reinstating wages, benefits, or employment rights that were denied,

· Referring victims to specialist support services,

· Supporting victims with legal assistance or access to justice.

‍

Step 5: Corrective Action for Offenders

· Work with suppliers to address and correct violations.

· Suggested – Where serious or repeated violations occur, ACS may remove suppliers from its approved or prefer suppliers list to uphold ethical standards.

· Share learnings to prevent recurrence across the supply chain.

‍

6. Responsibility

· Board of Directors: Overall responsibility for oversight of remediation actions.

· Senior Management: Day-to-day responsibility for case management, escalation, and reporting.

· All Staff: Obligation to report concerns immediately if they suspect any form of modern slavery.

‍

7. Monitoring & Review

· All remediation cases will be documented and reviewed to ensure effectiveness.

· Outcomes will form ACS’s annual Modern Slavery Statement.

· This policy will be reviewed annually and updated in line with new best practice and legislation.

· We would also recommend reading this in conjunction with our other policies, including our:

· Corporate social responsibility policy,

· Anti-bribery / corruption policy.

· Whistle blowing policy.

This policy was agreed by the Board of Directors on 19/09/2025 and is reviewed annually to ensure alignment with current legislation.