🛑Anti-Slavery and Human Trafficking Policy

Company Name: Hot Shots Recruitment Ltd

Registered Office: 321 Garretts Green Lane, Birmingham B33 0TU

Policy Status: Mandatory for all staff, clients, and suppliers Last Updated: December 2025

1. Policy Statement

Hot Shots Recruitment Ltd is committed to the highest standards of ethical conduct and social responsibility. We have a zero-tolerance approach to modern slavery and human trafficking in all forms. We are committed to ensuring our business operations and supply chains are free from slavery and exploitation, upholding the principles set out in the Modern Slavery Act 2015.

This policy applies to all individuals working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, contractors, consultants, and business partners.

2. What is Modern Slavery?

Modern slavery encompasses slavery, servitude, forced or compulsory labour, and human trafficking, all of which involve depriving an individual of their liberty by another for personal or commercial gain.

  • Slavery: Exercising powers of ownership over a person.

  • Servitude: The obligation to provide service that is imposed by coercion.

  • Forced/Compulsory Labour: Work or service exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.

  • Human Trafficking: The movement of people by means of threat, force, coercion, abduction, or deception for the purpose of exploitation.

3. Our Recruitment Operations

As a recruitment staffing agency, we recognise the inherent risks within the labour supply chain. We are committed to preventing slavery and trafficking by ensuring that:

  • Vetting and Due Diligence: We conduct robust identity checks and ensure all Applicants have the legal right to work in the UK before placement.

  • Fair Wages: We ensure that all placements meet or exceed the statutory minimum wage requirements and that Applicants are aware of their salary and payment terms.

  • Voluntary Work: We ensure that no Applicant is forced to work against their will and that their engagement is strictly voluntary.

  • Direct Engagement: We deal directly with Applicants wherever possible to verify their identity and consent without intermediary coercion.

4. Our Supply Chains and Suppliers

We expect the same high standards from all of our contractors, suppliers, and business partners.

  • Supplier Compliance: We include contractual terms requiring suppliers to comply with all applicable anti-slavery and human trafficking laws.

  • Risk Assessment: We conduct risk assessments on new and existing suppliers, particularly those operating in higher-risk sectors or geographies.

  • Termination: We reserve the right to immediately terminate contracts with any supplier found to be in breach of this policy.

5. Reporting and Communication

5.1. Employee Responsibility

All employees of Hot Shots Recruitment Ltd must familiarise themselves with this policy. If any employee suspects or becomes aware of any activity that may lead to or indicate modern slavery or human trafficking, they must report it immediately to their Manager or a Director.

5.2. Whistleblowing

We encourage openness and will support anyone who raises a genuine concern in good faith under our internal whistleblowing procedure, even if their concern turns out to be mistaken. We are committed to ensuring no one suffers detrimental treatment as a result of reporting their concerns.

6. Training and Awareness

We provide appropriate training to relevant employees, particularly those involved in recruitment, human resources, and supplier management, to ensure they understand the risks of modern slavery, the key indicators of exploitation, and how to respond appropriately.

7. Review

This policy will be reviewed and updated annually, or as required by new legislation, to ensure its effectiveness.

Approval: This policy is approved by the Directors of Hot Shots Recruitment Ltd and is available on the company intranet/website.