Modern Slavery Policy

Introduction

At Penta Consulting Group, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.

Our business and supply chains

Penta Consulting Groupis a Professional Services organisation specialising in helping clients find the very best IT Technical Resource. We operate in 10 countries across EMEA. As a recruitment business, Penta Consulting maintains relationships with many different organisations in its supply chain, as well as employing directly a large number of workers.

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We haven’t been made aware of any allegations of human trafficking/slavery activities against any of our suppliers.

Risk assessment

In the past year, we conducted a risk assessment of our supply chain by taking into account:

  • The risk profile of individual countries based on the Global Slavery Index

  • The business services rendered by the suppliers

  • The presence of vulnerable demographic groups

  • A news analysis and the insights of labour and human rights groups

    This assessment will determine our response and the risk controls that we implement.

Our Employees are required to understand modern slavery procedures to help prevention of it and to help conduct the business in a manner that any occurrence of modern slavery is avoided. Penta should also ensure that adherence to this policy forms part of the employment obligations under their contract of employment.

Policies

Penta Consulting Ltd operates the following policies for identifying and preventing slavery and human trafficking in our operations:

    • Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. We provide a confidential helpline to protect the identity of whistle-blowers.

    • Code of Conduct – our code encourages employees and Contractors to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee and Contractor conduct and ethical behaviour when operating abroad and managing our supply chain.

    • Supplier contracts – we have updated our supplier contracts to make explicit reference to slavery and human trafficking.

Supplier due diligence

Penta Consulting Ltd conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. Penta are committed to ensuring that its business is carried out with transparency and that our approach to deal with modern slavery is spread across to our Contractors, Subcontractors and Clients, and remains in line with the obligations under the Modern Slavery Act 2015.

Our processes are drafted in a specific way that helps to enforce specific prohibitions against the use of forced, compulsory or trafficked labour. All of our Contractors, Subcontractors and Clients are expected to act with the same approach.

Our Employees are required to understand modern slavery procedures to help prevention of it and to help conduct the business in a manner that any occurrence of modern slavery is avoided. Penta also ensures that adherence to this policy forms part of the employment obligations under their contract of employment.

Our measures includes:

  • Assessing risks in the provision of particular services

  • Auditing the suppliers, and their health and safety standards, labour relations and employee contracts

  • Conducting audits and risk assessments to determine which parts of the business require extra efforts and focus.

  • Engaging with our clients, suppliers and contractors to instigate a better understanding of modern slavery and human trafficking and to ensure that modern slavery does not occur in their businesses.

  • If appropriate, introducing screening programmes and self-reporting of our suppliers.

  • Ensuring that modern slavery policy provisions remain as part of the clients’, suppliers’ and contractors’ contractual relationship with the right to audit their activities

  • Ensuring all our Contractors are supplied and have accepted adherence to our Code of Conduct as part of the onboarding process

We require all Suppliers, Subcontractors and Contractors to attest that:

  • They don’t use any form of forced, compulsory or slave labour

  • Their employees work voluntarily and are entitled to leave work

  • They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment

  • They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reasons

  • They don’t require employees to surrender their passports or work permits as a condition of employment

Awareness & Training

All employees are expected to encourage openness and support with regards to genuine concerns. Penta shall ensure that no one suffers any detriment as a result of reporting any suspicion of modern slavery. Penta Consulting Ltd has raised awareness of modern slavery issues by conducting Modern Slavery Awareness as part of the Company Induction for all new Starters to the business and sending annual updates via a Company wide email to all staff that is focused specifically on modern slavery, which explains:

  • Our commitment in the fight against modern slavery

  • Red flags for potential cases of slavery or human trafficking

  • How employees should report suspicions of modern slavery

Measuring how we're performing

Penta Consulting Ltd has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:

    • How many employees have completed mandatory training?

    • How many suppliers have filled out our ethics questionnaire?

    • How many suppliers have rolled out an awareness and training programme that is equivalent to ours?

    • How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues?

    • What are the findings of our cross-functional Human Rights checks, which reviews, how we are addressing modern slavery and human trafficking?

Have all Contractors read and accepted our Code of Conduct?

This statement shall initially be adopted on 1st April 2021 and shall be reviewed by the Company’s Board of Directors on a regular basis, (at least annually) and may be amended from time to time.

This has been approved by the board of Penta Consulting Limited at the board meeting on 08th April 2021.

Kris England-Smith
Group Operations Director