MODERN SLAVERY POLICY

Published in accordance with the Modern Slavery Act 2015, this statement outlines the steps taken by Keystream Group to prevent modern slavery and human trafficking throughout our supply chains or in any part of our business.

KEYSTREAM GROUP’S STRUCTURE

Keystream was established in 2011 by Andrew Jukes and Johnny Stein.

Operating solely in the UK, Keystream provides non-clinical Healthcare, Charity and Government organisations recruitment services to the public and private sector across both contract and permanent vacancies across the UK. The types of roles include but are not limited to IT, Finance, Procurement, Marketing and Commissioning.

We are a niche recruitment consultancy supplying interim & permanent IT specialists into the NHS. Private Health, Charity and Government organisations and other private healthcare organisations.

We employ 35 people at our Head Office site based in Old Street, London.

All the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff.  All the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies.

The company operates an accredited ISO Quality Management System, with integrated policies, processes and procedures for all business activities and operations.

KEYSTREAM GROUP’S CURRENT POSITION

• Keystream Group takes its responsibility for ensuring the risk of modern slavery and human trafficking is minimised across its supply chain.
• Our supply chain is minimal and solely relates to the operation of the business and services to our clients and contractors.
• We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
• Keystream Group solely operate in the UK, as such we believe we operate in a “low risk” location for Modern Slavery.
• We ensure strict compliance checks are carried out for all workers supplied or managed by us. We verify the identity of each temporary worker and verify the worker’s right to work.
• In order to ensure that our suppliers are compliant, we have an umbrella company PSL which we regularly review and audit before recommending to our candidates.
• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
• We have a long standing relationship with the large majority of our supply base. We continue to see and speak to our main suppliers regularly to maintain and grow these relationships. We undertake due diligence when considering taking on new suppliers and regularly review our existing suppliers.
• We are active members of our UK trade body – Recruitment & Employment Confederation (REC) and ensure all our policies and procedures meet or exceed their levels.
• We recognise that knowledge is key and all employees must complete our mandatory Modern Slavery training and actively encourage employees to report any suspicious activity.

Keystream Group have a whistleblowing policy in place that is intended to provide a process for and protection to employees and staff who wish to raise genuine concerns regarding, amongst other things, our business practices. Keystream Group expects its staff to report concerns of non-compliance, no matter how trivial, in line with the established policies and procedures.

Whilst as an Organisation we believe we are in a low risk environment, during 2021 we will implement further staff training to ensure all staff are fully aware of the Modern Slavery Act 2015 and both their personal and the organisation’s responsibilities under the act. This will include areas such as:

• How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation.
• What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.

Our policy (below) reflects our commitment to act with integrity and ethically in all our business relationships and to implement and enforce effective systems and controls, including in relation to combatting modern slavery and human trafficking in our supply chains.

This policy is updated each year to ensure it is consistent with recent legal developments and recommended good practice as well as making express reference to modern slavery in a supply chain as an example of a potential concern staff might disclose under the policy.

1. POLICY

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

1.2 Keystream Group has a zero-tolerance policy to modern slavery and 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 in any of our supply chains

1.3 Keystream Group is also 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. We expect the same high standards from all of our Contractors, Suppliers and other Business Partners.

1.4 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.

1.5 This policy does not form part of any employee's contract of employment and we may amend it at any time.

2. RESPONSIBILITY FOR THE POLICY

2.1 The Management Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations.

2.2 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.

3. COMPLIANCE WITH THIS POLICY

3.1 You must ensure that you read, understand and comply with this policy.

3.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3.3 You must notify your Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

3.4 You are encouraged to raise concerns about any issue or suspicion of modern slavery at the earliest possible stage.

3.5 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible. The matter will then be referred on to HR and be dealt with in conjunction with the necessary agencies or third parties.

3.6 We 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 knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.

4. COMMUNICATION AND AWARENESS OF THIS POLICY

4.1 Training on this policy, and the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary.

4.2 Our commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

5. BREACHES OF THIS POLICY

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

5.2 We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.