ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY
Document Owners: A Meah and B Gill Last Revised: 1st February 2017
As an organisation, Opus Talent Solutions maintains relationships with many different organisations in its supply chain, as well as supplying varying levels of contract, interim, temporary and permanent workers. In the light of the general law on employment and human rights, and, more specifically, the Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine what existing measures are undertaken and what further measures may be required to prevent slavery and human trafficking taking place in any part of our businesses or supply chain during the financial year ending 31st December 2016.
Opus Talent Solutions has adopted a statement of our corporate values on the prevention of modern slavery and human trafficking. This value statement governs all our business dealings and the conduct of all persons or organisations with whom we contract directly or who we appoint to act on our behalf.
We expect all who have, or seek to have, a business relationship with Opus Talent Solutions and/or any member of our company, to familiarise themselves with and act at all times in a way which is consistent with our commitment to act ethically and with integrity.
Opus Talent Solutions AND ANTI-SLAVERY
As part of our culture of good governance for good business, Opus Talent Solutions conducts our business in line with a set of core values which are reflected in our relationships with our customers, stakeholders, suppliers and team members.
All our business relationships, our processes and our procedures are built on foundations of ethics and integrity, which is reflected in our zero tolerance approach to the exploitation of individuals in any form, and more particularly the offences under the Modern Slavery Act 2015.
We are therefore committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings.
PURPOSE OF THIS POLICY
Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which deprive an individual of their liberty as other persons exploit them for personal or commercial gain.
This document sets out the policy of Opus Talent Solutions (the “Company”) with the aim of the prevention of opportunities for people linked to our business to be treated as commodities, to occur within its businesses or supply chain. For the avoidance of doubt, this policy’s use of the term “modern slavery” has the same meaning given in the Act.
As a recruitment and staffing business operating in global markets, we recognise that we may have a greater responsibility than most to establish appropriate methods of assessing, preventing and mitigating risk of modern slavery occurring in their supply chains and organisation.
Opus Talent Solutions operates a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or those of our suppliers.
STEPS FOR THE PREVENTION OF MODERN SLAVERY
We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our supply chains, we acknowledge that we do not control the conduct of individuals and organisations in our supply chains. However, we have a suite of Company policies (including Business Ethics, Corporate Social Responsibility, Code of Conduct, Discipline and Grievance and Whistleblowing Policy) that define what is acceptable and expected in terms of behaviour in our Company, and all our employees are managed within these parameters.
This approach is reflected in the management of the supplier relationships too. We expect the same high standards from all of our contractors, suppliers and other business partners, and we are evolving and updating our contracting processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.
To underpin our compliance with practical steps, we intend to implement the following measures:
Supplier Relationships and Supply Chain in General
- conduct and review all risk assessments annually to determine which parts of our business and which of our suppliers are most at risk of modern slavery so that efforts can be focused on those areas;
- aim to build long lasting business relationships with reputable suppliers, contractors and sub-contractors
- at point of engagement with any new suppliers and during quarterly/annual reviews, convey our position regarding Anti-Slavery either as an introduction or as a reminder, and gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
- where appropriate, as informed by our risk assessment, seek to introduce supplier pre-screening (for example as part of our tender process) and self—reporting for our suppliers on safeguarding controls;
- introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.
- inform and gain agreement from all suppliers that we expect all members of our supply chain to at least adopt a ‘one up’ due diligence approach on the next link in the chain
Internal Operations – Training, Processes and Compliance
- All prospective employees will be interviewed against a set of core competencies that we deem to be inextricably linked to our organisations core values. Once hired, adherence to Company expectations in terms of conduct, behaviour and performance forms part of all team members’ obligations under their contract of employment.
- At point of hiring, all new employees will be referenced (wherever possible) and will undergo a Company induction and on the job training which will outline the processes and procedures
- All processes and procedures related to recruitment service provision (both internal and external) will be defined in such a way as to mitigate the risk of modern slavery occurring. These processes will include (but will not be limited to) Right to Work Checks, provision of certain personal information before starting work
- A ‘Compliance Team’ will be established and will take responsibility for auditing processes on a monthly basis, or more frequently if deemed necessary
- Establish an appropriate reporting system to encourage reporting of concerns and ensure the protection of whistleblowers in line with the Company Whistleblowing policy and procedure. For the avoidance of doubt, the Company Whistleblowing policy will be amended to cover concerns of Modern Slavery and/or Human Trafficking.
RESPONSIBILITY FOR THE POLICY
Ultimate responsibility for the prevention and prevention of modern slavery rests with the Company’s leadership team. The board of directors of the Company has overall responsibility for ensuring this policy and its implementation complies with our legal and ethical obligations.
A cross-functional team composed of representatives from Sales, Marketing, Finance, HR, Systems, IT and Operations will be established. This team will have functional knowledge and expertise of department specific policies, procedures and supplier relationships, and will therefore be best placed to:
- ensure those reporting to them understand and comply with this statement, and are given adequate, regular training on the issue of modern slavery
- appropriately assess areas of risk within the departmental supply chain and general operations
- work collaboratively to establish long term partnerships with reputable, tried and tested suppliers for the group irrespective of location etc
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously.
However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations.
Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.
COMMUNICTION AND AWARENESS OF THIS POLICY
Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Following its initial adoption, this Anti-Slavery and Human Trafficking Policy will be reviewed by the Company’s Senior Directors and the cross functional team nominated by the business on a regular basis (at least annually) and may be amended from time to time.
Confidentiality and trust are integral to JD Ross Energy and we wholly endorse the intent of the GDPR which is to ensure transparency, fairness and an increased confidence in the security of the data for the individuals whose data we hold.
Preparing for the requirements of the GDPR by 25th May 2018 has high priority in the business and has the full support of the management team and board.
We’d like to put your mind at rest about cookies. If you are uncertain about what a cookie is have a look at our simple guide to find out how we use them on our website.
WHAT IS A COOKIE?
Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie.
Cookies do lots of different jobs, like letting you navigate between pages efficiently remembering your preferences, and generally improve your web site experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
We can split cookies into 4 main categories:
- Category 1: strictly necessary cookies
- Category 2: performance cookies
- Category 3: functionality cookies
- Category 4: targeting cookies or advertising cookies
CATEGORY 1 – STRICTLY NECESSARY COOKIES
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like register for job alerts, cannot be provided.
- Please be aware our site uses this type of cookie
CATEGORY 2 – PERFORMANCE COOKIES
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
- By using our website and online services, you agree that we can place these types of cookies on your device.
CATEGORY 3 – FUNCTIONALITY COOKIES
These cookies allow the website to remember choices you make (such as your user name and password) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites.
- By using our website and online services, you agree that we can place these types of cookies on your device.
CATEGORY 4 – TARGETING COOKIES OR ADVERTISING COOKIES
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisations.
USING FEATURES ON OUR WEBSITES
We use a session cookie called SESSION_COOKIE. We do not store private data in it and the cookie is automatically removed when the users session ends.
Cookie name: SESSION_COOKIE
Category: 1 – Strictly necessary cookie
Purpose: To retain settings about the current visit to one of websites.
FOR MEASURING WEB TRAFFIC
Cookie name: _utma
Category: 2 – Performance cookie
Purpose: Saves information about total number of visits to the site, the time of the first visit, previous visit and current visit. This is a persistent cookie with a lifespan of 2 years.
Cookie name: _utmb
Category: 2 – Performance cookie
Purpose: Used to record information about what happened during the current visit or session, including the ability to tell when a session ends.
Cookie name: _utmc
Category: 1 – Strictly necessary cookie, 2 – Performance cookie
Purpose: Session cookie that expires at the end of the current session/visit.
Cookie name: _utmz
Category: 2 – Performance cookie
Purpose: Saves info relating to how a user arrived at a site, the channel though which they came, date/time info and what keywords they used if they arrived via a search engine.
ou can find out more about Google cookies here http://www.google.co.uk/policies/privacy/
FOR SOCIAL SHARING AND REFERRALS
Half an hour
For more information on Share This cookies visit http://sharethis.com/privacy
Who are we?
We are Opus Talent Solutions, incorporated as Opus Professional Services Group Limited. Our registered address is Portwall Place, Portwall Lane, Bristol BS1 6NA and you can contact us by email at firstname.lastname@example.org or by telephone on +44 (0) 117 968 9292.
Opus Talent Solutions is a global group of companies which provides talent solution services, including permanent and temporary recruitment services, to clients looking to recruit personnel for their businesses. We have offices in Bristol, London, Reading, Manchester, Amsterdam, New York, Sydney and Hong Kong and details of all our group companies can be found at the end of this Policy.
For the purposes of compliance with local laws in force from time to time, the registered entity in your market or who you do business with will be the data controller.
Opus Talent Solutions takes data protection seriously and aims to comply with best industry practice and all local laws. The application of this policy may be varied in accordance with local legal requirements and we may issue a country specific notice setting out specific provisions and practices in that jurisdiction.
What does this Policy cover?
We at Opus Talent Solutions take your personal data seriously. This Policy:
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data
- sets out the legal basis we have for using your personal data
- explains the effect of refusing to provide the personal data requested
- explains the different rights and choices you have when it comes to your personal data
- explains how we may contact you and how you can contact us.
What personal data do we collect about you?
We collect information about you which enables us to find available opportunities and assess your suitability throughout the recruitment process. This is collected in our capacity as a recruitment agency, recruitment business and talent consultancy as well as an employer if you want to work for us.
We collect personal information including but not limited to your first name, surname, email address (both personal and business), telephone number, residential address, job title, company name, financial information, job function, location, sector, CV, identification documents, evidence of right to work (RTW), educational records, work history, next of kin and emergency contact details, references and links to your professional profiles available in the public domain and on social media, such as LinkedIn and corporate websites.
We may also collect sensitive personal data about you, in the form of health or medical information (including details of any special assistance you may need or any sick leave taken during previous roles), racial or ethnic origin, sex life or sexual orientation, political opinions, religious beliefs, trade union membership and biometric data. We only collect sensitive personal data from you, and further process this data, where you have given your explicit consent.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide whether searching for a new opportunity, during the different recruitment stages or at a recruitment or networking event. This may be by telephone, email or in person.
- From an agent/third party acting on your behalf. This may be your own limited company, an umbrella company or another recruitment agency.
- Through publicly available sources. We use the following public sources:
- Social media and networking sites, including LinkedIn
- Job Boards that you have registered your details on.
- Companies House (or equivalent in the relevant jurisdiction)
- Corporate websites
- By Reference or word of mouth. For example, you may be recommended by a friend, a former employer, a former colleague or even a present employer.
Where we collect your information through publicly available sources as set out above, we may do this with the aid of software programmes, such as Daxtra, Lusha and idibu. These programmes are given parameters on the requirements of a role and search through publicly available sources to find such candidates. They are designed to only output information on candidates that meet the search criteria. Where we use these programmes, their use is restricted to only searching for information (e.g. job title, location, skillset) from public sites where there is a reasonable expectation that such information may be collected and used by recruiters for the purpose of sourcing candidates for different job roles.
How and why we use your personal data?
We will use your data so that we can provide our services to you, including:
- To match your skills, experience and education with a potential employer or client or current job opportunities.
- To provide more detailed information to a client, should you be chosen by the client to go through to the next stage.
- To keep you informed of job opportunities which we think may be of interest to you.
- To send you other information that may be of interest to you, such as workshops, events and newsletters from Opus Talent Solutions.
- To provide career guidance and management.
- To respond to your requests or questions when you contact us.
- To carry out our contractual obligations with you or with a client, including under any contracts we intend to enter into with you.
- To analyse trends in industry, although this information will be anonymised.
- To third parties (see below).
- If you work for a client or a potential employer looking to fill roles, to contact you about prospective candidates or leads and to share your contact details with a candidate, at interview stage and beyond.
- To provide services relating to talent management, including recruitment, talent consultancy, market mapping and research and salary surveys.
- To manage our relationship with you and with our clients and perform administrative and operational tasks.
- To comply with our legal obligations and rights, under contracts and at law, and to cooperate with authorities and investigations.
What marketing communications do you send?
We may send marketing communications to you by email, through social media, SMS or by post. You may opt out of receiving any further marketing communications by clicking the “unsubscribe” link in an email received from Opus or by contacting us at email@example.com.
How long do we keep your personal data for?
We keep your information for as long as you want us to and to use your information as described above. Please note that we may retain some of your information after you cease to use our services if it is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
Our standard policy is to retain personal information for 3 years but when determining the relevant retention periods, we will take into account:
- Our contractual obligations and rights in relation to the relevant information;
- Legal obligations under applicable law to retain data for a certain period of time;
- Our legitimate interest where we have carried out a balancing test;
- Statute of limitations under applicable law;
- Disputes, whether potential or actual;
- If you have made a request to have your information deleted;
- Guidelines issued by relevant data protection authorities.
If we determine that we can delete your data, we will do so securely.
Who do we share your personal data with?
Your personal data may be shared with certain third parties who will be subject to contractual obligations of confidentiality and compliance with relevant laws, including
- Our client who has a position to fill or who you may have been placed with. Our clients are global and based in numerous industries, such as IT, data management and analytics, financial services, architecture, energy and utilities, and in both the public and private sector.
- The end client or customer who you may be placed with through another agency or intermediary (for example where there is a managed service arrangement or where our client is a consultancy firm)
- Other recruitment agencies or service providers such as umbrella companies, RPO or PSL providers.
- Other companies and employees within the Opus Talent Solutions group
- Suppliers, contractors and agents who may perform services for us, including payroll providers, umbrella companies, professional advisers such as accountants or lawyers, insurance brokers, consultants, background check agencies, email marketing agencies, event organisers.
- Government or law enforcement authorities or any other third party in any jurisdiction, if we believe that we have an obligation to do so or that such action is necessary to protect, defend or enforce our rights.
- In the event of a sale, merger, liquidation, receivership or transfer of assets of any member of our group, to any third party provided they are obliged to only use your personal data for the purposes that you have provided it to us.
We may also conduct checks on you to verify the information you have provided and where we do this we may share your information with former employers or clients.
What legal basis do we have for using your information?
For prospective employees, candidates, contractors, referees and clients, our processing is necessary for our legitimate interests in that we need the information in order to be able to assess suitability for potential roles, to find potential candidates and to contact clients and referees.
We carry out a balancing test to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. We keep a record of these balancing tests which you can find out more about by contacting us using the details below.
If you are interviewed and submitted as a candidate, then this may involve the processing of more detailed personal data including sensitive data such as health information that you or others provide about you. In that case we always ask for your consent before undertaking such processing.
We may also rely on our processing being necessary to perform a contract for you, if you are a client or a candidate or contractor and we are negotiating or have entered into an agreement with you to provide services to you or receive services from you.
Processing may also be necessary to fulfil our legal and regulatory obligations, such as disclosure to public authorities, regulators and investigations.
We may also use your information if we have to establish, exercise or defend legal claims or where the personal information is in the public domain. The legal basis for this processing activity is that it is in the public interest.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data we request or withdraw your consent for the processing of your personal data, we may not be able to match you with available job opportunities.
Do we make any automated decisions concerning you?
No, we do not carry out automated profiling as there is an element of human intervention in all our processing.
Do we transfer your data outside the EEA?
Yes, to better match your employee profile with current opportunities we may transfer your personal data to members of the Opus Talent Solutions group, clients and partners in countries outside the EEA (being the 27 Member States of the EU plus Norway, Leichtenstein and Iceland). This includes the US, Hong Kong and Australia and other countries where our clients or processors may be located.
These countries’ privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have security measures and contractual clauses in place to protect your personal data.
By submitting your personal data, you agree to this transfer, storage or processing.
To find out more about how we safeguard your information as related to transfers contact us on firstname.lastname@example.org.
What security measures do we have in place?
We have appropriate technical and organisational security measures in place to protect your personal information under our control and to prevent unauthorised access, destruction, transmission, misuse or alteration of it. However, we cannot guarantee that such unauthorised access, destruction, transmission, misuse or alteration will not happen.
Transfer of data via the internet is not completely secure and while we do our best to protect your personal data, any data you transmit to us is at your own risk. Once we have received your data we will follow our procedures and policies to protect it.
If we share any links to external websites operated by other organisations (such as clients, training providers etc) with you, any data you submit to those websites (including clicking on any link) is outside our control and will be subject to that third party’s data protection and privacy policies. We cannot guarantee that any third party will be compliant with relevant laws and best industry practice and accept no responsibility or liability for these third parties.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
|Rights||What does this mean?|
|1. The right to be informed
|You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy.|
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
|3. The right to rectification||You are entitled to have your information corrected if it’s inaccurate or incomplete.|
|4. The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.|
|5. The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|6. The right to data portability||You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|7. The right to object to processing||You have the right to object to certain types of processing, including processing for direct marketing or if you no longer want to be contacted with potential opportunities.|
|8. The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.|
|9. The right to withdraw consent||If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.|
|We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
· baseless or excessive/repeated requests, or
· further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by phone, email or via social media or networking sites. If you prefer a particular contact means over another please just let us know.
How can you contact us?
We will review your personal data to ensure it is up to date and accurate but rely on your cooperation to keep us informed if any such data changes. If you would like to change any information you have provided to us, please just let us know.
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here:
FAO Data Protection Officer,
Opus Talent Solutions Group, Portwall Place, Portwall Lane, Bristol BS1 6NA, UK
Or at the registered office of any of our group companies listed below, marked for the attention of Data Protection Officer
tel: +44 (0) 117 968 9292
Registered in England and Wales. Registered office: Portwall Place, Portwall Lane, Bristol BS1 6NA
- Opus Professional Services Group Limited (registered number 9117554)
- Opus Recruitment Solutions Limited (registered number 6470842)
- JDR Energy International Limited (registered number 9489793)
- McLean Ross Limited (registered number 7802817)
- Addocura Limited (registered number 9384507)
- Talentcubed Limited (registered number 8653285)
- Avion Recruitment Solutions Limited (registered number 9843200)
- Mensio Consulting Limited (registered number 9892534)
- Avion Innovation Limited (registered number 10151526)
- Hinton Spencer Architecture Limited (registered number 10500351)
- Colston Consulting Trading Limited (registered number 10240380)
- Opus Dormant Limited (registered number 10010851)
- 3Focus Limited (registered number 9669456)
Opus Recruitment Solutions Holland B.V. (Chamber of Commerce number: 62199064). Herengracht 282, Paleis op de Dam, 1016 BX Amsterdam
Opus Recruitment Solutions – Australia Pty Limited (ACN: 601349464 ABN: 93 601 349 464). Level 29, Chifley Tower, 2 Chifley Square, Sydney, NSW 2000, Australia
Opus Professional Services Group (USA) Inc (Delaware). Trolley Square, Suite 20C, Wilmington, 19806, County of New Castle, USA
JDR Energy (USA) Inc (Delaware). 135 E 57th Street New York NY10022, USA
Opus Financial Services (USA) Inc (Delaware). 135 E 57th Street New York NY10022, USA
Opus Recruitment Solutions (USA) Inc (Delaware). 135 E 57th Street New York NY10022, USA
Opus Recruitment Solutions Hong Kong Limited (Hong Kong). 10/F., Mass Mutual Tower, 33 Lockhart Road, Wan Chai, Hong Kong