Carrington Umbrella Limited – Modern Slavery Statement 2022/2023
This statement sets out Carrington Umbrella’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 6 April 2022 to 5 April 2023.
We recognise that we have a responsibility to take a robust approach to slavery and human trafficking. Carrington Umbrella operates a zero-tolerance approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. Organisational structure and supply chains.
This is a single statement to cover the activities of Carrington Umbrella Limited. In our industry, routinely, when an employment business fills a temporary vacancy for a client, the employment business will either payroll the individual directly or refer him/her to a preferred supplier. We are preferred/approved suppliers for many recruitment businesses in the UK. Once the individual has been referred to us, we employ him/her to work on temporary assignments for end clients/users. In some scenarios, individuals will also contact us directly, asking for our employment while they carry out a temporary assignment(s) for a client.
The supply chain proceeds as follows:
- The client contacts a recruitment business to source an individual to assist with its workload. A contract for services is normally signed between the two businesses.
- The recruitment business will contact and verify a suitably qualified and/or experienced person to fulfil the client’s vacancy.
- The recruitment business refers that individual to Carrington Umbrella or alternatively, the individual advises the recruitment business that he/she wishes to be employed by Carrington Umbrella.
- Carrington Umbrella and the recruitment business sign a contract for services for the supply of the individual to the recruiter’s client.
- Carrington Umbrella employs the individual on a contract of employment. This is the end of the supply chain.
- In the alternative, an individual will contact us directly and we will arrange and sign a contract for services with the client for the supply of the individual to the client. This is the end of the supply chain.
Countries of operation and supply
Carrington Umbrella currently operates exclusively in the UK. Workers may be asked to work abroad on assignments with their clients. Our insurance covers this scenario except for the USA. Carrington Umbrella’s head office is based in London and our Umbrella employees are placed all over the country.
The Directors are responsible for the organisation’s anti-slavery initiatives, with the support of the team. Their duties involve:
- Policies: The review and implementation of all policies relating to modern slavery and human trafficking risks.
- Risk assessments: The identification of risk and steps needed to mitigate the risk of modern-day slavery.
- Investigations/due diligence: To investigate and take due diligence steps in relation to known or suspected instances of slavery and human trafficking.
- Measure and evaluate success: To measure the effectiveness of our due diligence to ensure that slavery and human trafficking is not taking place in the business or supply chains.
- Training: continue to raise awareness of modern-day slavery risks.
Due diligence processes and steps
We have taken the following steps to prevent slavery and human trafficking in its business and supply chain:
We regularly review our Modern Slavery Policy which 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 anywhere in our supply chains. Our Modern Slavery Policy is available on request and on our website
We will not support or deal with any businesses knowingly involved in slavery or human trafficking. The recruitment businesses that we work with are reputable businesses and we expect them to follow the same anti-slavery policies as we do.
We follow a strict agency/client on-boarding process as follows:
- Completion of our Client registration form
- Digital Right to Work check
- We adhere to the national minimum wage (NMW). Our systems restrict us from processing a payment below the NMW and our employment contract with the worker also reiterates this point.
- All payments are made to the employee’s personal bank account
- We continue to monitor key case law
- Completion of our New Agency form
- Carry out due diligence for example checks on recruitment agencies(accreditation/compliance standards/modern slavery policy
- We have developed a whistle blowing policy to encourage our employees, officers orsubcontractors to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The whistleblowing procedure was designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, officers or sub-contractors or others who have concerns can contact the directors on a confidential basis.•
- Legislation was introduced in April 2019 that required employers to show hours on payslips where the pay varies by the amount of time worked. All Carrington Umbrella payslips record accurate•The effectiveness of our workFollowing a review of the effectiveness of the steps we have taken this year to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking in the year 2022/2023:
- Continue to risk assess the business and focus our efforts on those departments most of risk of being used for modern slavery, particularly around NMW and our onboarding procedures.
- Continue to monitor in respect of other expected changes and work towards compliance where required.
- Monitor the proposed Modern Slavery Bill
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Carrington Umbrella’s slavery and human trafficking statement for the financial year ending 5th April 2022. The statement has been approved by the Directors, who will review and update it annually.