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Modern Slavery Policy

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Anti-Slavery and Human Trafficking Statement

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Refine Recruitment Limited ("Refine") provide recruitment services to clients across the UK.

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Our supply chain consists primarily of:

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- Candidates we recruit and place into roles  
- Third party recruitment agencies we partner with
- Vendors providing goods and services for business operations

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Policy Statement:

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Refine has zero tolerance for modern slavery and human trafficking. We are committed to acting ethically and upholding human rights in all of our business relationships. We will safeguard against any form of modern slavery within our operations and supply chain.

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We understand that modern slavery encompasses:

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- Forced labour obtained through threat, coercion, abuse, or deception
- Human trafficking for exploitation  
- Being controlled or deprived of freedom by an employer or recruiter
- Being dehumanised and treated as a commodity or property
- Having restriction of movement or confinement

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Our Commitment:

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- We comply with the UK Modern Slavery Act 2015 and take active steps to prevent slavery and human trafficking.  
- We routinely perform due diligence on our supply chains to identify and mitigate any risks.
- We mandate that suppliers, subcontractors, agencies and partners confirm their compliance with our policy. We discontinue any relationships where non-compliance or hidden issues are found.
- We strive to ensure no labour utilised for our benefit is obtained through illegal or unethical means. We adhere to all employment laws.
- Our Managing Director holds ultimate accountability for this policy's implementation and provides training to all employees.

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Risk Assessment & Monitoring:

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- We conduct frequent risk assessments focused on high risk regions, industries, and recruitment supply chain partners. 
- We survey and audit suppliers to verify their hiring, vetting, and labour practices align with our standards.
- We include clear contractual terms mandating supplier adherence to our policy.
- We track supplier policy implementation, benchmark against peers, and report metrics to leadership.
- We provide confidential reporting mechanisms and thoroughly investigate all policy violation claims.

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Continual Improvement:

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Upholding our commitment requires constant re-evaluation and enhancement of procedures. We review our actions annually for effectiveness and aim to regularly strengthen training programmes.

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This statement applies to our 2023 financial year and beyond.

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Signed:

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Devina Henry

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Managing Director

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