AM2PM POLICY ON PREVENTING HIDDEN LABOUR EXPLOITATION

 

1. POLICY STATEMENT

1.1 AM2PM commits to developing and adopting a proactive approach to tackling hidden labour exploitation.

Hidden labour exploitation is exploitation of job applicants and workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management.  It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation.  It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.

2. COVERAGE

2.1 This policy covers any workers within AM2PM Group Holding Ltd, which Includes subsidiaries AM2PM Recruitment Solutions (Birmingham) Ltd and AM2PM Retail Services Ltd.

3. RESPONSIBILITY

3.1 Alan McGeorge and Pete McSheffrey, Directors, have overall responsibility of this policy.

3.2 Branch Managers have specific responsibilities for various aspects of this policy, in relation to the registration of candidates.

4. POLICY COMMITMENTS

AM2PM shall:

A. Designate appropriate employees to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.

B. Accept that job-finding fees are a business cost and will not allow these to be paid by job applicants.  The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work-finding fee.

C. Ensure that all staff responsible for directly recruiting workers are trained to be aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Registration Principles.

D. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.

E. Prevent individuals, however seemingly well-intentioned to introduce significant numbers of workers for work (accepting that word of mouth introductions to close friend and family are likely harmless).

F. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Labour Abuse Authority (GLAA) – and police when necessary.    

G. Provide information on tackling “Hidden Labour Exploitation” to our workforce through Induction training, ongoing training and Registration Principles sign-offs.  

H. Encourage workers to report cases of hidden third-party labour exploitation, provide the means to do so and investigate and act on reports appropriately.

I. Positively encourage and support employees and agency workers to report such exploitation that may be occurring within their communities by telling a trusted Manager, contacting the AM2PM HR Department or contacting the GLAA Report Line.

J. Provide its workers with a multi-language confidential helpline through which issues can be raised confidentially by phone, as well as providing independent interpreting during investigations and complaints.

K. Provide posters and leaflets in our branches that are multi-lingual to encourage victims of trafficking and forced labour to report their exploitation. 

L. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.

5. INDICATORS OF LABOUR EXPLOITATION

5.1 There are a number of indicators of trafficking and forced labour. Not all of the indicators will apply in every case, some may not be immediately apparent and there is no set number of signs that will indicate that a person is a victim of labour exploitation. One or a combination of factors may suggest that a person is victim of labour exploitation.

5.2 Indictors may include:

5.2.1.  Restricted Freedom

  • Not be in possession of their documents such as passports or other travel ID.
  • May only travel with other workers.
  • Unable to communicate freely with others.
  • Unable to leave their place of work by themselves.

5.2.2. Behaviour

  • Unfamiliar with the local language.
  • Allows others to speak on their behalf.
  • Have limited or no social interaction.
  • Shows fear or anxiety.

5.2.3. Accommodation

  • Not know their home address.
  • Lives in a group at the same address.

5.2.4. Finances

  • Provide bank details of another person for their wages to be paid into.
  • Not be in possession of their bankcard / documents.

5.3.5. Appearance

  • Wears the same clothes every day or inappropriate clothes for the season.
  • Has injuries that appear old, untreated or that they cannot explain.
  • Suffers injuries that appear to be the result of an assault.

6. WHAT TO DO?

Should a Director, employee or worker have any suspicions of human trafficking, forced labour or worker exploitation they should report their concerns to the HR Department immediately. It is AM2PM’s duty to seek assistance for those vulnerable workers.

It is important to remember that under the circumstances special measures must be taken to help a vulnerable person.  AM2PM will seek guidance and assistance from external bodies such as the GLAA and police to ensure that assisting victims is conducted sensitively, appropriately and safety.

 7. WHERE TO FIND FURTHER INFORMATION

Gangmasters Labour and Abuse Authority: www.gla.gov.uk

UK Human Trafficking Centre: www.nationalcrimeagency.gov.uk

Migrant Help: www.migranthelp.org

8. REPORTING

In the first instance, where possible, any suspicions should be reported to the HR Department. In emergencies outside of office hours, your suspicions can be reported to: 

The police – 101 or 999

Crimestoppers – 0800 555 111

The GLAA – 0800 432 0804 or 0115 959 7032

UK Slavery Helpline – 0800 012 1770

UK Human Trafficking Centre – 0844 778 2406