Modern Slavery and
Human Trafficking Statement
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 and South Africa 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
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 commitment to combatting modern slavery. To further enable us to ensure compliance we have implemented additional checks in our supply chain onboarding and audit processes in 2024. Part of this update was to ensure suppliers signify their commitment to combatting Modern Slavery by agreeing 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 incidences of modern slavery in the workplace and that they can either a) make a confidential and anonymous report using our companywide "Confidential Reporting" tool; or b) make a report directly to the Modern Slavery Helpline.
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 will continue to review the management of our supply chains, being especially mindful of our presence in the global market, to ensure our suppliers continue to meet the standards that we expect.
Statement made following financial year ended April 2025
Group Chief Operating Officer
Adam Herron