PeoplePlus Slavery and Human Trafficking Statement

We are proud of the conditions of employment for all our employees throughout PeoplePlus. Given the nature of our business, our senior management board considers that there is minimal risk approximating that, either within PeoplePlus or through our supply chains supporting our business activities, that are in any way involved in or even tangentially supportive of, or complicit in slavery and human trafficking.

The employment and procurement practices operated by the businesses within PeoplePlus ensure that we are rightly viewed as an excellent and supportive employer. And to the extent that our organisation operates as a purchaser of goods or services we expect a high level of ethical conduct from those businesses with which we do business within our supply chain.

Organisation Structure

PeoplePlus is an employment support and training services company helping people transform their lives and businesses through work, training, education and financial services. We help people move into work by enabling them to gain the skills they need to make them employable, providing them with real work experience or helping them onto a traineeship or apprenticeship. We do this as a prime provider on behalf of the Department for Work and Pensions and the Education & Skills Funding Agency and the European Social Fund. We also work with employers who we can offer a personalised recruitment and training solution for their business; we manage the whole process from vacancy profiling to candidate sourcing, vetting and selection.

Our Supply Chain

Our supply chain enables us to help more people into work. Our partners are established public and private sector organisations that help us to deliver and maintain high quality job coaching, recruitment and skills development services. The aim of our partnerships is to join forces and expertise in offering a service that can seamlessly fit the needs and requirements of jobseekers, employers and skills learners alike. We work with a variety of established partners who are committed to the same high standards. This is validated through our due diligence processes and for those organisations that meet the threshold of obligations under the section 54 (1) of the Modern Slavery Act 2015 we will support our partners to understand those obligations and statutory duties.

Anti-Slavery Policy Statement

PeoplePlus has zero tolerance to slavery and human trafficking and is committed to ensuring that there is no modern slavery or human trafficking in any part of our business. This Anti-Slavery Policy Statement is the principal articulation of the PeoplePlus stance on slavery and human trafficking. It is intended to inform and influence all the operational procedures within the organisation. Our stated Anti-Slavery Statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure (amongst our other priorities) that slavery and human trafficking is not taking place anywhere in our business or related supply chains.

Due Diligence and Implementation Processes

As part of our initiative to identify and mitigate risk (including in relation to that of human trafficking and slavery) we operate a range of policies and procedures appropriate to the different sectors of PeoplePlus. These include the policies and procedures in the following areas:

− Anti-Bribery and Corruption Policy

− Anti-Money Laundering Policy

− Supply Chain Design

− Supply Chain Review

− Consultancy Policy

− Whistle-blowing Policy

− Recruitment Policy

− Safeguarding Policy

− Prevent

– Anti-Radicalisation and Extremism Policy

− Equality and Diversity Policy

PeoplePlus also articulates a series of employee rights and benefits available to employees during the employee Inductions and Welcome Events and individual contracts of employment for each member of staff. PeoplePlus operates a HR department led by the HR Director and a Governance department led by the Governance Director.

Each of the Company’s Directors and the Managing Director have reviewed and agreed to the terms of this statement. Each of these departments has reporting responsibilities to the Senior Management Board. A combination of procedures and functions operates to help identify, assess and monitor potential risk areas in our supply chains and mitigate the risk of slavery and human trafficking occurring in our supply chain.

Training

We will communicate this statement to all our staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business and in future will include references as part of the Company’s training, induction and information materials.

Legal and Regulatory Purpose of this Statement

This statement is made with regard to the obligations arising under section 54(1) of the UK’s Modern Slavery Act 2015 (the Act). Accordingly this statement should be considered to constitute the slavery and human trafficking statement for PeoplePlus for the 2019 financial year and all future financial years until it may in future be modified or amended.

Steven Bell

Governance Director

For and on behalf of PeoplePlus Group Limited