SLAVERY AND HUMAN TRAFFICKING STATEMENT 

Organisational Structure & Supply Chain

Elbrus Point is a specialist recruitment business that provides IT and Technology experts and candidates to clients on a contract basis and/or for permanent employment. Since its incorporation in 2015, Elbrus Point has widened its reach considerably, dealing with both domestic and international (especially European) clients and contractors.

Our supply chains include (but are not limited to) sourcing candidates for clients, which may involve the introduction of candidates to third party companies, for onward supply to our clients. 

Our Policies on Slavery & Human Trafficking

Elbrus Point recognises our responsibility to take a robust approach to slavery and human trafficking and we are committed to preventing the same in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking. Our policies reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our business and in our supply chains. Our policies, which we review annually, include: 

• HR Procedures – We operate a zero-tolerance policy of any threat of physical or sexual violence, harassment or intimidation against employees. Our policies are clearly defined and communicated to all employees either via training sessions or through written policies which are easily accessible and available to all employees via our employee handbook. All of our employees are treated fairly and equally. We check that all our staff have the appropriate right to work documents and ensure that they are paid fairly and enjoy a competitive remuneration package;

• Whistleblowing Policy – Elbrus Point is committed to protecting employees when disclosing malpractice and ensuring that any disclosures made in good faith will be treated confidentially and without fear of retaliation. We provide annual compliance training to all employees, which includes guidance on how to report suspected dangers or wrongdoing in the workplace; 

• Health and Safety Policy – a key aim of this policy is to ensure the wellbeing of our employees and anyone who may be affected by our activities;

• Our Values – Elbrus Point values of Relentless, Ambitious, Committed and Accountable makes clear to our employees the actions and behaviour expected of them when representing Elbrus Point. We strive to maintain the highest standards of employee conduct and ethical behaviour.

Elbrus Point encourages our suppliers and potential suppliers to strive for high ethical standards and to operate in an ethical, legally compliant and professional manner. We also expect our suppliers to promote similar standards in their own supply chain. Suppliers are expected to adhere to our Supplier Code of Conduct, which sets out the standards we expect. Elbrus Point selects suppliers not only on the basis of cost and quality but with due consideration given to other factors such as ethical, environmental and social policies

Due Diligence Processes for Slavery & Human Trafficking

As part of our commitment to identify and eradicate slavery and human trafficking, we have in place a process to undertake due diligence on our supply chain network to ensure compliance with legislative obligations; such compliance forms part of our contractual relationship with suppliers. We regularly review and audit our suppliers for purposes of ascertaining compliance with relevant laws and regulations in order to be reconfirmed for our Approved Supplier List. Where services supplied by candidates in the public sector are deemed to be within IR35, we conduct due diligence checks to ensure that candidates are engaged via an umbrella company or on the payroll of a company so that they are correctly set up for PAYE purposes. In order to ensure that our suppliers are also compliant with the Modern Slavery Act 2015, we include a question on modern slavery and trafficking in our due diligence questionnaire for our Approved Suppliers List, which is reviewed annually.

Elbrus Point ensures strict compliance checks are carried for all candidates we supply. We carry out identity, right to work and referencing checks. When required to do so by the client we also carry out additional checks, including DBS and detailed employment and address history for a number of years prior to the engagement.

All Elbrus Point employees have access to dedicated channels through which they may voice concerns, either through local reporting mechanisms or through the whistleblowing procedure.

As a business we will continue to monitor our operations to ensure these are in line with the MSA, as well as advance our dedication to human rights and sustainability through regular reviews of our internal policies.

Training

We regularly carry out training with all of our employees (both those working in Sales areas or Operations) to ensure that they are kept informed and updated of relevant laws and regulations. Training sessions include:

• All new joiners attend induction sessions which include information and training on our policies, relevant legislation and their duties, responsibilities and rights in relation to the same;
• Managers are provided with a range of leadership training and are assisted by our HR department in HR-related matters including recruitment, remuneration and employee wellbeing;
• Our Legal and HR departments conduct annual compliance training across the business on various topics including whistleblowing, anti-bribery, and discrimination.

This statement is made on behalf of Elbrus Point Limited pursuant to section 54(1) of the Modern Slavery Act 2015 (“The MSA”) and comprises our slavery and human trafficking statement.