Monitor Area
Alert Flag Current Status Further Action

Recruitment The individual with control over workers may seek to befriend the labour provider or frontline staff and offer to find them workers, often at short notice
All staff have been retrained in all aspects of our ethical compliance policies and procedures.
This included a module on Stronger
Together to raise awareness within the company at all levels of recruitment compliance principles.
All staff (regardless of whether recruiting or not have completed and returned the Recruiter Compliance
Principles.
All staff have been given a copy of the
Checklist of Good Practise to Identify
& Deter Hidden Labour Exploitation.
Stronger Together chain posters
(different languages) provided to senior management team.
Stronger Together leaflet provided to senior management team
Key members of management team and HR have attended formal
Stronger Together workshops.

Continued senior management presence at
Stronger Together workshops and to focus on the importance of this initiative when visiting sites and branches with recruiters.

Recruitment
Recruitment
Recruitment
Recruitment
A number of workers are introduced to the labour provider by a particular individual, usually of the same nationality, with good English language skills. This individual may claim he is a friend, relative, uncle, cousin etc., or just helping out but speaks for the other individuals and controls the conversation. S/he waits whilst the individuals are being interviewed.
Externally completed registration documents are in a significantly better standard of English than the applicant possesses.
A number of externally completed registration documents are brought in by one individual on behalf of his “friends” or
“family”.
A number of externally completed registration documents are brought in having been completed in the same handwriting.
As above
PMP policy does not allow for any documents to be completed outside of specific recruitment locations and candidates are not left alone to complete documents .
Recruiter Compliance principles reinforced above policy.
As above
No further action require

Recruitment
Workplace
Workplace
Workplace
Workplace
Workplace
Applicants appear frightened, agitated or secretive and act as if they are instructed by another.
As above and guidance given to all staff in the ethical and compliance workshop.
A third party rings in to book a friend or family as available for a work shift.
Workers say they rent from a landlord who works for the labour provider or labour user.
Registered workers keep turning up to see if work is available and appear to be accompanied by individual(s) who stay in the background.
Workers are delivered in minibuses or people movers, particularly where such transport is not licensed and/or the driver is not part of the permanent or agency work force
.
One worker supplies food in the workplace for a number of the agency workers.
As above and guidance given to all staff in the ethical and compliance workshop.
No further action required
No further action required

Workplace
Workplace
Workplace
Workplace
Records
Workers physical appearance may show signs of injury and malnourishment and their general appearance may be unkempt with inappropriate clothing.
A rise in the number of non-English speaking workers of a certain nationality where they are organised by a particular labour provider consultant or labour user supervisor of the same nationality.
A particular individual may stay close to a group of workers when anyone from authority is present.
As above and guidance given to all staff in the ethical and compliance workshop.
There is a need to improve the current demographic track of applicant pool vs. Consultant nationality.
A pattern where migrant workers of the labour providers or labour users workforce stop working suddenly for no particular reason.
Checking addresses shows high occupancy of particular houses of agency workers.
As above and guidance given to all staff in the ethical and compliance workshop.
As above and guidance given to all staff in the ethical and compliance workshop.
Different front end systems exist in the business.
No further action required


System alert flags and reporting has been
No further action required
No further action required


Group is reviewing front end systems highlighted as a need.
Group is reviewing front end systems
System alert flags and reporting has been highlighted as a need.

Records Checking bank accounts shows a number of unrelated workers paid into one account.
Bank account anomalies checks are completed once per week.
Group following statement in
November 2013
Cordant have implemented a new policy regarding workers sharing bank accounts. Workers can no longer share bank details unless they can prove that it is a joint bank account or they have the same surname as the worker they are sharing with. These details will be checked prior to the payroll being sent on a
Wednesday and anyone worker sharing bank details who have not proven it is a joint account or have differing surnames will be paid by cheque.
No further action required.
System alert flags and reporting has been highlighted as a need.

Records
Records
Records
Checking mobile phone numbers shows a number of unrelated workers contactable through one number.
Checking emergency contact numbers shows a number of unrelated workers contactable through one number.
Check documents for same next of kin and /or same place of origin/location in home country.
Different front end systems exist in the business.
There is currently no report or system in place to easily capture and check this information without significant manual intervention.

Group is reviewing front end systems

System alert flags and reporting has been highlighted as a need.

Review whether Managed Services are able to provide raw data for this reporting.

Review and determine whether this is needed given all other alert flag monitoring.