Modern Slavery and
Human Trafficking Statement
Foreword
Throughout the financial year ending April 2026, nGAGE Specialist Recruitment Limited
(“nGAGE”), together with each of our group companies covered by this statement, (a list of which you will find at the end) continued to strengthen its approach preventing modern slavery and human trafficking across our operations and supply chains. nGAGE acknowledges its significant position in the international recruitment
market and recognises that it must be held to the highest ethical standards for the fair treatment
of its workforce. During the year, we continued to invest in compliance systems and maintained mandatory modern slavery training across nGAGE. These measures support out commitment to ethical recruitment practices, worker welfare and responsible business conduct.
As a leading international recruitment group, we recognise our responsibility to identify and address
the risks of exploitation that can arise within labour markets
and supply chains. We remain
committed to maintaining the highest
standards of integrity and transparency, ensuring that all workers are treated
with dignity and respect and that any indicators of modern slavery,
human trafficking, forced labour or other forms of
exploitation are identified and addressed promptly.
Modern slavery can take many
forms within the recruitment sector, including forced labour, debt bondage, human trafficking, exploitative
working conditions and the abuse of vulnerable workers. We continue to review and enhance our policies, procedures
and compliance controls to
help prevent these risks, supported
by robust worker verification processes, supplier oversight and ongoing
colleague training. We also recognise the important role that effective identity verification and right
to work compliance play in protecting
workers from exploitation and
maintaining the integrity of labour supply chains.
Business Structure
nGAGE provides shared overhead and
support services to our recruitment and managed service businesses that 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 1,250 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 South Africa and Poland, together with colleagues in India and Pakistan via trusted partners who share the high
standards and requirements that the nGAGE Group demands.
This statement is made by nGAGE Specialist
Recruitment Limited and on behalf of those group
companies for which nGAGE has operational
oversight and which are covered by this statement. The covered entities are
listed in the table at the end of this statement.
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
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 in which the information is accessible and understandable
Protecting our Contingent Workers
nGAGE prohibits the charging of recruitment or placement fees to workers. We expect our suppliers, employment partners, employers of record, umbrella companies and labour providers to apply the same standard and we investigate any allegation that workers have been charged fees in connection with obtaining work.
We recognise that migrant workers and other vulnerable groups may face increased risks of exploitation. Our processes require additional scrutiny where indicators of vulnerability are identified, including concerns relating to debt, coercion, document retention, accommodation arrangements or restricted freedom of movement.
We undertake right to work checks on all workers in accordance with applicable immigration and employment legislation. We utilise compliant checking processes and maintain appropriate records evidencing each check whilst ensuring that original identity and immigration documents are never retained where this is prohibited by law or unnecessary for compliance purposes. We regularly review our right to work procedures to reflect legislative developments and Home Office guidance.
Where required we engage in-country experts to ensure we are compliant with each of the labour laws and taxation systems applicable to a country that we work in.
We prohibit the use of labour brokers who fail to comply with applicable employment and labour laws and maintain a zero-tolerance approach to child labour, forced labour, human trafficking and any form of modern slavery.
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 Anti-Slavery and Human Trafficking Policy provides the central framework for our opposition to modern slavery and human trafficking. It is supported by training, processes and procedures which are reviewed periodically to reflect changes in legislation, regulatory guidance and our operational requirements.
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.
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 record, 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.
Monitoring and effectiveness
We monitor the effectiveness of our approach through ongoing review of supplier due diligence, worker onboarding checks, compliance escalations, training completion and any concerns raised through our reporting channels. We will continue to assess whether additional performance indicators should be adopted to strengthen oversight and provide clearer evidence of the effectiveness of our controls.
Training
We continue to provide regular, mandatory training to our staff to 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 require our business partners and suppliers to provide appropriate training to their own staff. To support a consistent approach, certain training modules are made available directly 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 incidents of modern slavery in the workplace and thattheycan either a) make a confidential and anonymous report using our company-wide "Confidential Reporting" tool; orb) 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 recognises that further steps should always be considered.
We welcome the continued development of digital identity and right to work verification frameworks within the UK. We believe that appropriately designed digital verification processes can strengthen compliance, reduce opportunities for documentfraud and identity abuse, improve the protection of vulnerable workers and support efforts to prevent labour exploitation and modern slavery. As legislative requirements evolve, nGAGE will continue to adapt its onboarding and compliance procedures to maintain the highest standards of workforce verification and worker protection.
Robust right to work verification forms an important part of our approach to preventing modem slavery and human trafficking. Effective identity verification helps ensure workers are engaged transparently, discourages the use of false documentation and sup ports the identification of indicators of exploitation or coercion.
We will look to strengthen the review and management of supply chains, being especially mindful of our presence in the global market, to ensure that our suppliers continue to meet the standards that we expect.
Specifically, these entities are covered by this statement:
| Legal Entity | Trading name(s) |
| Agile Workforce Services Limited | Agile Insourcing; Agile Complex Care |
| Attenti Consulting Services Limited | |
| Butler Rose Recruitment Limited | |
| Caritas Recruitment Limited | |
| Community Resourcing Limited | Eden Brown Built Environment, RG Setsquare |
| Eden Brown Limited | Eden Brown Synergy |
| EWI Recruitment Limited | |
| GCS Recruitment Specialists Inc. | |
| GCS Recruitment Specialists Limited | |
| GCS Resources (Europe) Limited | |
| Holt Medical Recruitment Limited | Holt Doctors; Holt Nursing |
| Inner Circle Recruitment Systems Limited | Cyber Vacancies |
| I-Resource Inc | Bridge. VMS |
| I-Resource Limited | Bridge. VMS; Ryalto |
| JDR Energy International Limited | JD Ross |
| LMS Recruitment Systems Limited | |
| nGAGE Operations Limited | |
| nGAGE Proactive Technical Recruitment Limited | Proactive Global |
| 10 Select B.V | Proactive Global |
| nGAGE Specialist Recruitment SP.ZOO | |
| nGAGE Talent GMBH | |
| nGAGE Talent Inc. DBA | Proactive Global; EWI USA; Smart4Cloud; Smart4Energy; Smart4EPC; Smart4Sciences; The Innovation-Hub |
| nGAGE Talent Pty Limited | Smart4Energy in South Africa Proactive Global in Australia EWI in Australia GCS Recruitment Specialists in Australia |
| nGAGE Talent Solutions GmbH | |
| nGAGE Talent UK Employees Limited | |
| nHANCE Payroll Limited | |
| nology Consulting (Australia) PTY Limited | |
| nology Consulting Limited | |
| Opus Recruitment Solutions (USA) Inc | |
| Opus Recruitment Solutions Australia PTY Limited | |
| Opus Recruitment Solutions Europe Sociedad Limitada | |
| Opus Recruitment Solutions Holland B.V | |
| Opus Recruitment Solutions Limited | |
| Opus Talent Solutions (USA) Inc | |
| Opus Talent Solutions Limited | |
| Retinue Solutions Limited | |
| RX Delivery Solutions Limited | RX+ |
| nGAGE Recruitment Consultancy Limited | Smart4EPC; Smart4Sciences |
| Synergy Recruitment Consultancy Limited | Synergy Medical |
| The Anaesthetists Agency Ltd | |
| TOM B.V | |
| Westminster Specialist Recruitment B.V | |
| Westminster Topco Limited |
Board Approval
This statement has been approved by the Board of Directors of nGAGE Specialist Recruitment Limited and signed by a director on behalf of the Board.
Statement made following financial year ended April 2026.
Group Chief Operating Officer
Adam Herron