Modern Day Slavery Policy

Stronger Together – Tackling Modern Day Slavery

Recruit Mint Ltd - Modern Day Slavery & Hidden Labour Exploitation Policy

1. Policy Statement

Recruit Mint Ltd is committed to preventing modern slavery, human trafficking, forced labour, and hidden labour exploitation in all its operations and supply chains. We will act ethically and transparently, and take positive steps to safeguard workers from exploitation, forced work, or unfair recruitment practices.



We recognise that modern slavery and exploitation often occurs through third parties or hidden intermediaries, and we accept that addressing it requires vigilance, control, and ongoing improvement.

2. Scope / Applicability

This policy applies to:

  • All Recruit Mint operations, including permanent, contract, and temporary recruitment.
  • All employees, directors, officers, consultants, and contractors of Recruit Mint.
  • All clients, labour providers, subcontractors and supply chain partners, including second-tier labour providers or agencies used by clients or sub-contractors.
  • All recruitment and labour sourcing activities, whether in the UK or internationally.

3. Definitions

  • Modern Slavery: Encompasses slavery, servitude, forced or compulsory labour, human trafficking, and related exploitation.
  • Hidden Labour Exploitation: Exploitation by rogue third parties or individuals beyond the direct employer or labour provider (e.g. unauthorised intermediaries), such as forced use of accommodation, payment of recruitment fees by workers, or illegal deductions.
  • Labour Provider: Any third party entity that supplies, sources, or places workers on behalf of Recruit Mint or a client.
  • Worker: A person engaged by Recruit Mint or a labour provider (temporary workers, contractors, applicants).

4. Responsibilities & Governance

  • Director / Senior Management (e.g. Aaron Bowes): Overall accountability for the policy, ensuring adequate resources, oversight, and enforcement.
  • Designated Modern Slavery Lead / Compliance Officer: Responsible for operational oversight, coordinating risk assessments, investigations, training, reporting, audits, and supplier engagement.
  • Recruitment / Operations Teams: Ensure that recruitment practices, candidate screening, contracts, and supplier relationships comply with this policy.
  • All Employees & Workers: Required to report any concerns or suspicions of exploitation or non-compliance in recruitment, working conditions, or third-party arrangements.

5. Policy Commitments

Recruit Mint shall:


1. Prohibit recruitment fees

  • We will never charge job applicants or workers for job-finding services or recruitment costs; such costs are borne by us.
  • We will not engage with any labour provider or third party that requires workers to pay fees for recruitment or placement.

2. Risk assessment & due diligence

  • We conduct ongoing risk assessments of our business operations and supply chains to identify areas vulnerable to exploitation or forced labour.
  • Before collaborating with labour providers or subcontractors, we require them to demonstrate compliance with anti-slavery practices, provide policies, and permit audits or inspections.
  • We will include anti-slavery clauses in contracts with suppliers, labour providers, and subcontractors, with rights to audit, termination, and corrective actions in case of breaches.

3. Incident reporting & investigations

  • We encourage and protect any individual (employee, worker, contractor) to report suspicions of modern slavery, hidden exploitation, or forced labour.
  • Reports will be handled confidentially and sensitively, with protection against retaliation.
  • We will investigate all credible reports promptly and thoroughly, in coordination with legal, compliance, and, where necessary, law enforcement or regulatory bodies (e.g. Gangmasters & Labour Abuse Authority).
  • If we uncover exploitation, we will take corrective actions, including termination of relationships, remediation, and cooperation with authorities.

4. Training & awareness

  • Managers and staff engaged in recruitment, supplier management or worker liaison will receive training on modern slavery risks, red flags, and obligations.
  • All recruiters / consultants must sign compliance declarations acknowledging they understand and will abide by anti-exploitation principles.
  • Information, awareness materials, posters, leaflets, and induction modules will be used to alert workers, candidates, and third parties to rights and how to report concerns.

5. Worker engagement & communication

  • We provide clear channels for workers and candidates to raise concerns, ask questions, or report abuse anonymously if necessary.
  • We incorporate questions and checks into candidate interviews and worker questionnaires to detect potential exploitation (e.g. requests about accommodation, recruitment fees, withholding documents).
  • We maintain transparency with workers about their rights, contractual terms, pay, deductions, lodging, and responsibilities.

6. Monitoring, audit & review

  • Conduct periodic audits (internal or third party) of labour providers and supply chain partners to check compliance.
  • Monitor key indicators such as recruitment fees, complaints, unusual deductions, turnover in labour provider staff, and worker feedback.
  • Review this policy regularly (annually or sooner if circumstances change), and update controls, training, and risk assessments accordingly.


6. Supply Chain & Contractual Controls

All labour providers, subcontractors, and supply chain partners must sign written agreements confirming their compliance with this policy and with anti-slavery laws.


Contracts will include:

  • Right to audit / inspection
  • Right to terminate in case of breach
  • Obligation to notify us of any suspected exploitation
  • Clauses requiring transparency on recruitment practices, fees, deductions, and worker welfare


In high-risk sectors or geographies, we require additional due diligence (site visits, third party audits, certified ethical credentials).

7. Reporting, Whistleblowing & Protection

  • We provide multiple safe reporting channels, including confidential or anonymous reporting.
  • We guarantee non-retaliation / whistleblower protection: no worker or employee will be dismissed, penalised or discriminated against for raising a genuine concern or cooperating in an investigation.
  • If necessary, we may escalate substantiated violations to relevant agencies (e.g. the Gangmasters & Labour Abuse Authority, Police, or regulatory bodies).

8. Contact Information

Recruit Mint Ltd
17 Church Walk
Peterborough, Cambridgeshire, PE1 2TP
Email: peterborough@recruitmint.com
Phone: 01733 802300


If you have any questions, concerns, or suspect exploitation, please contact the Modern Slavery Lead or Compliance Officer immediately.