Anti‑Slavery and Human Trafficking Policy

1. Purpose and commitment

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ScaleOps Search Ltd (“ScaleOps”) adopts a zero‑tolerance approach to slavery, servitude, forced or compulsory labour, and human trafficking in its operations and the limited supply chain relevant to a micro recruitment business. This policy sets out the standards, controls and due diligence we apply to prevent, identify, and remediate modern slavery risks in our services. It is designed to comply with the spirit and letter of the Modern Slavery Act 2015 Section 54 guidance, even though ScaleOps is below the statutory turnover threshold.

 

2. Scope

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This policy applies to:

• The owner/Managing Director of ScaleOps and any contractors engaged by ScaleOps.

• All activities relating to candidate sourcing, screening, and placement, and to onboarding clients and third‑party service providers (e.g., background‑check vendors).

• UK operations and any occasional overseas engagements conducted from the UK.
   

3. Definitions (summary)

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• Modern slavery: situations of exploitation that a person cannot refuse or leave due to threats, violence, coercion, deception, and/or abuse of power; offences include slavery, servitude, forced or compulsory labour, and human trafficking.

• Employer Pays Principle (EPP): No worker should pay for a job; all recruitment‑related costs must be borne by the employer.

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4. Our standards

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ScaleOps will:

1. Prohibit worker‑paid fees and any deductions or charges linked to securing employment, consistent with the Employer Pays Principle.

2. Conduct right‑to‑work and identity checks for all placements and verify legitimate recruitment channels to prevent coercion or trafficking indicators.

3. Ensure informed consent: candidates receive clear information on roles, pay, location, hours, and any mobility or accommodation aspects before accepting offers.

4. Include anti‑slavery clauses and expectations in client terms, stating zero tolerance of forced labour and requiring clients to uphold the EPP and lawful employment practices.

5. Provide a confidential reporting channel (email/phone) for concerns, with a victim‑centred approach to remediation and referral to appropriate authorities or support services where needed.

 

5. Due diligence & risk assessment (proportionate for a micro business)

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5.1 Client onboarding

• Screen new clients for modern‑slavery governance (e.g., public statement/policy if applicable, complaint mechanisms, labour‑provider controls).

• Avoid high‑risk engagements where indicators suggest debt bondage, deceptive recruitment, or labour exploitation.
   

5.2 Candidate protection

• Verify candidate identity and right‑to‑work; watch for red flags (third‑party control of documents, shared bank accounts, debt obligations).

• Confirm that no recruitment fees were paid by the candidate; if identified, seek remediation with the employer in line with EPP.

 

5.3 Suppliers/third parties

• Where third‑party services are used (e.g., checks), select providers with clear anti‑slavery policies and whistleblowing channels.

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6. Training & awareness

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As a one‑person business, the owner will complete annual self‑learning using Home Office Transparency in Supply Chains guidance and sector resources to maintain awareness of indicators, remediation, and reporting best practices.

 

7. Reporting, escalation & remediation

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• How to report: Concerns can be raised confidentially via email or phone.

• Escalation: Where credible indicators exist, ScaleOps will document the case, notify relevant authorities when appropriate, and engage the client to halt harm and remediate (including repayment of any worker‑paid fees) in line with EPP.

• Non‑retaliation: No adverse action will be taken against any individual raising a good‑faith concern.

 

8. Monitoring & continuous improvement

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• Maintain a simple register of: client screenings, candidate checks, concerns, outcomes, and annual policy reviews.

• Review this policy annually (or sooner if guidance changes) and update public statements accordingly.
   

9. Governance

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• Owner responsibilities: Implement this policy, keep records, ensure compliance in all engagements, and act promptly on concerns.

• Public transparency: This policy is available on ScaleOps’ website.​

 

Signed:

Amie Capron, Managing Director, ScaleOps Search Ltd

Date: 18th July 2025

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Version: 1.0 | Effective from: 18th July 2025 | Approved by: Owner / Managing Director (Amie Capron)