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Business Name: E3 Recruitment Ltd

Business Type: Labour Provider

Industry Type: Food, Construction

Country: United Kingdom

Business Partner Year: 2023

Date of last submission: 02/08/2023

Business Partner Commitments
Evidence of Implementation
1. A senior manager has completed the following Responsible Recruitment Toolkit training in the last three years:
  • Introduction to Responsible Recruitment

Training name: Introduction to Responsible Recruitment

Joe Brownbill
Head of Legal & Compliance
Webinar
2023-06-21
2. The business has developed, implemented, and annually reviews a policy on:
  • Responsible Recruitment

The title of this policy may differ per business, e.g. for technical, contextual or legislative reasons.

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3. A senior manager has been appointed with overall responsibility for implementing the business Responsible Recruitment Policy in our operations and supply chain.
Yes
Joe Brownbill
Head of Legal & Compliance
4. The business has implemented at least 40% of the Responsible Recruitment Toolkit online tool steps
Upload PDF copy of the recently completed Summary Report, available to download at the bottom of the 'Dashboard' page showing 'progress tracking and reporting'.
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5. An established ongoing management system and training programme is in place to ensure key staff are aware of their responsibilities to address recruitment risks, including ensuring no recruitment fees are charged to workers, no child labour, transparent recruitment, opportunity and treatment are fair, equal and dignified, and effective labour supply chain due diligence, and how to provide effective remedy for any issues identified. Key staff can include:
  • Members of the senior management team
  • Supervisors and team managers
  • HR, Payroll and staff involved in direct recruitment
  • Worker and Trade Union representatives
  • Recruitment intermediaries
  • Sub-contracted Labour Providers

The Compliance and Payroll team attend regular training, ensuring that they are up to date with the current legislation as well as being able to spot the signs of modern slavery. Consultants, managers and directors attend training on how to spot the signs of exploitation. We self auditing ourselves annually as well as receive continuous audits from our labour users.
6. You implement ongoing awareness raising and engagement activities with workers. This can include:
  • Transparent recruitment
  • Offer letters/contracts contain information on no charging of recruitment fees
  • Displaying the Stronger Together workplace posters
  • Issuing Stronger Together worker leaflets to all workers (including any temporary, seasonal and contractor workers via the labour provider/recruitment intermediary/service provider)
  • Delivering training sessions
  • Promoting grievance and whistleblowing channels that are available to report concerns throughout recruitment and employment
  • Conducting team briefings
  • Conducting worker welfare interviews and including questions relating to key recruitment risks including recruitment fees, misinformation during recruitment, discrimination and harassment and whether any hidden brokers have been involved in recruitment
  • Collaborating with Trade Union representatives to engage workers
  • Inviting local support services/charities to speak to workers
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Our recruitment process exemplifies complete openness and transparency, adhering to the highest professional standards throughout its entirety. Each candidate is provided with a comprehensive Key Information Document, meticulously outlining the remuneration structure and detailing any deductions stipulated by HMRC. To further ensure transparency and clarity, every candidate receives a confirmation of assignment prior to commencing their employment. This document affirms essential details, including their hourly wage, stipulated working hours, overtime provisions, and other relevant aspects pertinent to their role. As part of our commitment to fostering a supportive and respectful work environment, all new workers are informed of the designated channels to confidentially report any grievances they may encounter. To underscore our dedication to a culture of integrity and accountability, we make our grievance and whistleblowing policy readily accessible, ensuring that employees are aware of their rights and the available mechanisms to raise concerns. By incorporating these measures, we uphold our unwavering pledge to prioritize transparency, fairness, and employee well-being at every stage of our recruitment and employment processes. We strive to instill confidence and trust in our workforce, nurturing an environment that fosters open communication and the protection of individual rights.
7. A session on Responsible Recruitment is incorporated into inductions for new workers, including any temporary, seasonal and contractor workers. Induction content may include one of the following:
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All new worker application forms include the following posters: 'Agency Workers & Your Rights' 'Gangmaster Victims Leaflet' GLAA Workers Rights'
8. You have mapped your labour supply chain: labour providers, recruitment intermediaries and subcontractors.
Yes
9. You regularly conduct pro-active checks for indicators of exploitation. These checks could include any of the following:

- Interviewing workers to identify:

  • The ways that they find out about jobs and whether there is any evidence of hidden or unauthorized individuals/businesses involved in the recruitment processare recruited
  • Where workers come from and how they travel?
  • Whether any intermediaries/third-party brokers/individuals/recruiters or other third-parties such as insurance or translation agencies are used
  • Whether other workers introduce job applicants
  • How workers are transported and by whom
  • How and where workers are housed and by whom

- Using and maintaining a Grievance Mechanism to pick up on worker issues

Yes
As part of our rigorous commitment to upholding ethical employment practices and safeguarding the welfare of our workforce, we will conduct periodic and randomized welfare interviews with our employees. Through these interviews, we will meticulously verify that no worker has incurred any improper or unauthorized recruitment fees, as such practices are strictly prohibited and incongruent with our core principles. Furthermore, during these interviews, we will diligently ascertain that all workers maintain full control over their respective bank accounts and accommodation arrangements. By ensuring that employees exercise autonomy over these crucial aspects of their lives, we aim to foster an environment of empowerment and dignity for our workforce.
10. The business has established how it will respond where a potential case of exploitation is identified, whether with directly employed staff, agency workers or on-site contractors. Any such reports are acted on appropriately.
Any concerns or complaints will be addressed in accordance with our formal grievance policy. The investigation process will be led by our Head of Legal and Compliance, in collaboration with the senior manager of the respective department and, where relevant, a representative from the end user. The collected findings will be consolidated into a comprehensive report, which will be further actioned based on the conclusions drawn from the investigation. In cases where indications of exploitation are identified, immediate steps will be taken to ensure the well-being and safety of the affected individual. Whenever feasible, the victim will be relocated to a secure environment. Additionally, appropriate authorities will be promptly notified to implement measures aimed at safeguarding the victim or worker in question.
11. The business is committed to share reports detailing the actions taken to implement responsible recruitment risks, reporting on the self-assessed progress with clients when requested, i.e. either as PDF reports or through the ‘Supply Chain’ level subscription functionality.
Yes
12. The business receives updates on issues and developments with regards to implementing responsible recruitment. Examples include:
Yes
Subscribed to several authorised bodies including RRT, Stronger Together, GLAA, ALP. Attend regular webinars with ALP / Stronger Together.