Modern Slavery Statement

ORGANISATION

This statement applies to Placing People Direct Ltd referred to in this statement as ‘the Organisation’. The information included in the statement refers to the financial year June 2026.

DEFINITIONS

The Placing People Direct Ltd considers that modern slavery encompasses:

· Human trafficking;

· Forced work, through mental or physical threat;

· Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;

· Being dehumanised, treated as a commodity or being bought or sold as property;

· Being physically constrained or to have restriction placed on freedom of movement.

 COMMITMENT

The Placing People Direct Ltd acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. 

The Placing People Direct Ltd understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Placing People Direct Ltd does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. 

No labour provided to the Placing People Direct Ltd in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Placing People Direct Ltd strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in UK.

 ORGANISATIONAL STRUCTURE

Sunita Nahar is the Founder and Director of Placing People Direct Ltd.
Company. Registered Number: 12391127.
Head office is at: Kemp House, 160 City Road, London, England, EC1V 2NX.

An independent recruitment agency who specialises for the education sector.

 We supply permanent fully qualified staff from early years to the higher education at all levels across England. Organisations and the public domains needs met.

The labour supplied to the Placing People Direct Ltd in pursuance of its operation is carried out in the UK only. 

 SUPPLY CHAIN STRUCTURE

In order to fulfil its activities, Placing People Direct Ltd main supply chains relate to the recruitment, placement, and employment support services provided to the education and childcare sectors across the United Kingdom.

Our supply chain primarily consists of applicant’s seeking employment opportunities, educational settings and employers, and other professional service providers that support the delivery of our recruitment services.

As an education recruitment business, our supply chain is relatively straightforward and predominantly UK-based. We work directly with schools, nurseries, colleges, local authorities, training providers, and childcare settings to source and place suitably qualified and vetted candidates into permanent, temporary, and apprenticeship roles. We also engage with external organisations that provide essential compliance services, including safeguarding checks, training, payroll support, insurance, and administrative systems.

We recognise that some of our first-tier suppliers may themselves rely on additional subcontractors and lower-tier suppliers to deliver their services. For example, software providers may utilise third-party hosting services, and training providers may engage external assessors or accreditation bodies. While we do not have direct contractual relationships with these lower-tier suppliers, we expect all organisations within our supply chain to operate ethically and comply with all applicable legislation, including the Modern Slavery Act 2015.

Placing People Direct Ltd is committed to conducting business with integrity and transparency. We adopt a zero-tolerance approach to modern slavery, servitude, forced labour, and human trafficking. As part of our due diligence processes, we seek to work with suppliers and partners who share our values and demonstrate appropriate policies and procedures to safeguard against modern slavery risks within their own operations and supply chains.

We recognise that the risk of modern slavery within our direct operations is relatively low due to the nature of our business. However, we remain vigilant and continue to review our supply chain relationships, procurement practices, and safeguarding procedures to identify and mitigate any potential risks.

 ORGANISATIONAL POLICIES

Placing People Direct Ltd has implemented a range of policies and procedures that reinforce our commitment to preventing modern slavery, servitude, forced labour, and human trafficking within our operations and supply chains. These policies promote ethical business practices, safer recruitment, safeguarding, and compliance with relevant legislation.

Our key policies include:

· Modern Slavery Policy – setting out our zero-tolerance approach to modern slavery and our commitment to complying with the requirements of the Modern Slavery Act 2015.

· Safer Recruitment and Recruitment Policy – outlining the procedures for recruiting, vetting, and placing candidates within education and childcare settings, including identity checks, right to work verification, DBS requirements, and compliance obligations.

· Safeguarding and Child Protection Policy – ensuring that the welfare and protection of children and vulnerable individuals remain central to all aspects of our work.

· Equality, Diversity and Inclusion Policy – promoting fairness, equal opportunities, dignity, and respect for all individuals and prohibiting discrimination, harassment, and exploitation.

· Whistleblowing Policy – encouraging employees, candidates, clients, and stakeholders to report concerns regarding unethical conduct, safeguarding matters, or suspected modern slavery without fear of retaliation.

· Anti-Bribery and Corruption Policy – outlining our commitment to conducting business honestly, ethically, and in accordance with applicable legislation.

· Data Protection and Confidentiality Policy – ensuring compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 in the handling of personal information.

· Corporate Social Responsibility (CSR) and Social Value Policy – demonstrating our commitment to creating positive social impact, supporting local communities, promoting inclusive employment opportunities, and conducting business responsibly.

· Supplier and Partner Code of Conduct – setting out the standards of behaviour and ethical expectations we require from suppliers, contractors, and business partners, including compliance with employment legislation and the prohibition of forced labour and exploitation.

 

Copies of these policies are available upon request. As our website is currently undergoing redevelopment, policy documents can be obtained by contacting us directly at sunita@placingpeopledirect.co.uk

Placing People Direct Ltd regularly reviews and updates its policies to ensure they remain effective, proportionate, and aligned with current legislation and best practice. We expect all employees, associates, suppliers, and business partners to uphold these standards and share our commitment to eradicating modern slavery in all its forms.

ASSESSING AND MANAGING RISK

Placing People Direct Ltd considers its main exposure to the risk of slavery and human trafficking to arise within the wider recruitment and supply chain activities associated with sourcing, vetting, and placing applicants into employment opportunities within the education sector.

As a recruitment business, our direct operations are predominantly UK-based and are therefore considered to present a relatively low risk of modern slavery. However, we recognise that risks may exist in the following areas:

· Candidate recruitment and placement activities, particularly where applicants may be vulnerable to exploitation due to language barriers, limited understanding of their employment rights, financial hardship, immigration status, or dependency on third parties for accommodation, transport, or employment arrangements.

· Engagement with third-party suppliers and service providers, including training providers, payroll providers, compliance services, IT suppliers, and other professional partners, where there may be limited visibility of their own lower-tier supply chains and employment practices.

· Overseas qualifications and international applicants, where there may be varying employment standards and safeguarding practices. Appropriate checks and verification processes are therefore undertaken to confirm eligibility, authenticity of documentation, and suitability for work in the United Kingdom.

· Subcontracted or outsourced services, where first-tier suppliers may rely on additional contractors or service providers. Although we do not have direct contractual relationships with these lower-tier suppliers, we expect all organisations we engage with to comply with applicable employment legislation and uphold ethical working practices.

Placing People Direct Ltd recognises that individuals seeking employment can, in some circumstances, be at greater risk of exploitation. We are therefore committed to identifying and responding to any indicators of forced labour, debt bondage, coercion, trafficking, or other forms of exploitation through robust recruitment, safeguarding, and compliance procedures.

To mitigate these risks, we undertake safer recruitment checks, verify candidates' identities and right to work in the United Kingdom, promote safeguarding awareness, encourage the reporting of concerns through our whistleblowing procedures, and seek to work only with suppliers and partners who share our commitment to ethical business conduct and compliance with the Modern Slavery Act 2015.

We recognise that the risk of modern slavery can evolve over time and, as such, we regularly review our policies, procedures, and supply chain relationships to identify, assess, and minimise any potential risks within our operations and those of our business partners.

In general, Placing People Direct Ltd considers its exposure to slavery and human trafficking to be relatively limited, due to the nature of its operations as a UK-based education recruitment business.
The majority of our activities involve the recruitment and placement of the applicants into schools, nurseries, colleges, and other educational settings within the United Kingdom, operating within a highly regulated environment.

Nonetheless, we recognise that no organisation is entirely free from the risk of modern slavery and human trafficking. We are committed to taking appropriate steps to ensure that such practices do not occur within our own business operations or within the organisations that supply goods and services to us.

To mitigate these risks, Placing People Direct Ltd has implemented a range of measures, including:

· Maintaining a zero-tolerance approach to modern slavery, servitude, forced labour, and human trafficking;

· Conducting safer recruitment and compliance checks, including verifying identity and right to work documentation where applicable;

· Working with reputable suppliers, contractors, and service providers that are expected to comply with all relevant employment and human rights legislation;

· Requiring employees, associates, and business partners to uphold ethical standards and report any concerns relating to exploitation or unethical practices;

· Providing clear policies and procedures, including our Modern Slavery Policy and Whistleblowing Policy, to encourage the reporting and investigation of concerns;

· Reviewing our supply chain relationships and procurement practices periodically to identify and address any potential risks; and

· Promoting safeguarding awareness and a culture of integrity, accountability, and transparency throughout the organisation.

Placing People Direct Ltd remains committed to continuously monitoring and improving its practices to prevent modern slavery and human trafficking and to ensuring that all individuals connected with our business are treated fairly, ethically, and with dignity and respect.

 DUE DILIGENCE IN RELATION TO MODERN SLAVERY

A) Placing People Direct Ltd carries out due diligence processes to help ensure that slavery, servitude, forced labour, and human trafficking do not take place within our organisation or throughout our supply chains. We recognise our responsibility to operate ethically and to take reasonable and proportionate steps to identify, assess, and mitigate the risk of modern slavery.

B) As part of our due diligence procedures, we undertake the following actions:

C) Supplier Due Diligence: We seek to engage with reputable suppliers, contractors, and service providers that share our commitment to ethical business practices and compliance with relevant legislation, including the Modern Slavery Act 2015. Where appropriate, we request confirmation that suppliers have suitable policies and controls in place to prevent modern slavery within their own operations and supply chains.

D) Review of Supplier Controls: We periodically review our relationships with key suppliers and professional partners, including payroll providers, training organisations, IT providers, compliance services, and other third-party suppliers, to ensure they continue to meet our ethical and legal expectations.

E) Safer Recruitment Processes: As an education and childcare recruitment business, we implement robust recruitment procedures designed to protect candidates and clients from exploitation. These include identity verification, right to work checks, confirmation of qualifications where applicable, safeguarding considerations, and compliance with relevant recruitment legislation and guidance.

F) Whistleblowing and Reporting Mechanisms: We maintain procedures that encourage employees, candidates, clients, and stakeholders to report any concerns relating to unethical conduct, exploitation, safeguarding issues, or suspected modern slavery. All concerns are taken seriously and investigated appropriately.

G) Policies and Procedures: We have implemented policies that support our zero-tolerance approach to modern slavery, including our Modern Slavery Policy, Safer Recruitment Policy, Whistleblowing Policy, Safeguarding Policy, Equality, Diversity and Inclusion Policy, and Supplier Code of Conduct.

H) Staff Awareness and Training: We promote awareness of safeguarding responsibilities, ethical conduct, and indicators of exploitation within our organisation. Employees and associates are encouraged to remain vigilant and understand the importance of identifying and reporting concerns relating to modern slavery and human trafficking.

I) Applicant Protection: We seek to ensure that all individuals engaging with our services are treated fairly, understand the terms of any employment opportunities, and are not subjected to coercion, discrimination, or exploitative practices. We encourage candidates to raise concerns should they feel vulnerable or believe they are being treated unfairly.

J) Ongoing Monitoring and Review: We regularly review our policies, procedures, and supply chain arrangements to identify any emerging risks and to ensure that our approach remains effective, proportionate, and aligned with current legislation and best practice.

K) Through these measures, Placing People Direct Ltd aims to minimise the risk of modern slavery within its operations and supply chains and demonstrates its commitment to conducting business with integrity, transparency, and respect for human rights.

 TRAINING

Placing People Direct Ltd is committed to ensuring that all employees, associates, and relevant stakeholders understand the risks associated with modern slavery and human trafficking and are equipped to identify and respond appropriately to any concerns.

To effectively implement our zero-tolerance approach to modern slavery, we provide and promote the following training and awareness initiatives:

· Induction Training: All employees and associates are introduced to the organisation's values, ethical standards, safeguarding responsibilities, and commitment to preventing modern slavery and human trafficking as part of their induction process.

· Modern Slavery Awareness Training: Staff are made aware of the provisions of the Modern Slavery Act 2015, the indicators of modern slavery and exploitation, and the procedures for reporting any concerns or suspicions.

· Safeguarding Training: Given the nature of our work within the education and childcare sectors, staff are encouraged to undertake safeguarding training, which reinforces the importance of recognising vulnerabilities, protecting individuals from harm, and escalating concerns appropriately.

· Safer Recruitment Training: Employees involved in recruitment activities receive guidance on safer recruitment practices, including recognising potential indicators of exploitation, verifying documentation, conducting appropriate checks, and ensuring ethical recruitment processes are followed.

· Whistleblowing Awareness: Staff are informed of the organisation's Whistleblowing Policy and encouraged to report concerns relating to unethical conduct, exploitation, safeguarding matters, or suspected modern slavery without fear of retaliation.

· Equality, Diversity and Inclusion Training: Training and guidance are provided to promote respect, dignity, equality of opportunity, and awareness of the needs of vulnerable individuals and those who may be at increased risk of exploitation.

· Ongoing Professional Development: Employees are encouraged to participate in additional e-learning and professional development opportunities to ensure that their knowledge remains current and aligned with emerging risks, legislative changes, and best practice guidance.

Placing People Direct Ltd recognises that awareness and education are essential in preventing modern slavery. We are committed to regularly reviewing our training arrangements to ensure that employees remain informed, vigilant, and confident in identifying and addressing any concerns relating to slavery, servitude, forced labour, and human trafficking.

 MONITORING AND EVALUATION

Placing People Direct Ltd has established the following key performance indicators to measure the effectiveness of the actions taken to prevent modern slavery and human trafficking within our organisation and supply chains:

· Zero substantiated incidents of modern slavery identified within our direct operations.

· 100% of employees and associates to be made aware of the organisation's Modern Slavery Policy and reporting procedures through induction and ongoing communication.

· Completion of safeguarding and compliance training by relevant staff involved in recruitment and candidate engagement activities.

· Regular review of key suppliers and business partners to ensure they continue to meet our ethical standards and comply with applicable legislation.

· Investigation and appropriate action taken in response to all concerns raised relating to potential exploitation, unethical practices, or modern slavery.

· Annual review and update of policies and procedures, including the Modern Slavery Policy, Whistleblowing Policy, and Supplier Code of Conduct, to ensure they remain effective and aligned with current legislation and best practice.

· Monitoring of recruitment and placement practices to ensure safer recruitment procedures, identity verification, and right to work checks are consistently applied.

· Maintenance of clear reporting mechanisms, with records kept of any concerns raised, investigations undertaken, and outcomes achieved.

· Promotion of a culture of transparency and accountability, encouraging employees, candidates, suppliers, and stakeholders to report concerns without fear of retaliation.

The effectiveness of these measures is reviewed on an ongoing basis by the management team. Any identified areas for improvement are incorporated into the organisation's action plans to strengthen our approach to preventing modern slavery and human trafficking.

Placing People Direct Ltd is committed to continuous improvement and recognises that monitoring, evaluation, and regular review are essential to ensuring that our policies and procedures remain effective in protecting individuals from exploitation and upholding human rights throughout our operations and supply chains.

Placing People Direct Ltd evaluates the effectiveness of its actions to prevent modern slavery and human trafficking through regular monitoring, review, and continuous improvement of its policies, procedures, and working practices.

We assess our effectiveness by:

· Reviewing any reports, complaints, whistleblowing disclosures, safeguarding concerns, or allegations relating to modern slavery, exploitation, or unethical practices, and ensuring that all concerns are investigated and addressed appropriately.

· Monitoring compliance with our safer recruitment procedures, including identity verification, right to work checks, and other pre-engagement requirements.

· Confirming that employees and associates have been made aware of our Modern Slavery Policy, Whistleblowing Policy, and safeguarding responsibilities through induction and ongoing communication.

· Reviewing supplier and partner relationships periodically to ensure that they continue to demonstrate a commitment to ethical business practices and compliance with relevant legislation.

· Recording and monitoring any identified risks, incidents, or areas of concern and implementing corrective actions where necessary.

· Reviewing the effectiveness of staff training and awareness initiatives by seeking feedback and identifying any additional training requirements.

· Conducting an annual review of our Modern Slavery Statement and associated policies to ensure they remain current, proportionate, and aligned with legislative requirements and best practice guidance.

· Monitoring developments in legislation, government guidance, and sector expectations to strengthen our approach to identifying and mitigating the risks of modern slavery within our operations and supply chains.

Through these measures, Placing People Direct Ltd aims to maintain a culture of vigilance, transparency, and accountability. We recognise that preventing modern slavery requires ongoing commitment and continuous evaluation, and we remain dedicated to improving our practices to safeguard the rights and dignity of all individuals connected with our business.

STEPS

Steps Taken to Prevent Modern Slavery (Section 54(4), Modern Slavery Act 2015)

Placing People Direct Ltd has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Placing People Direct Ltd has taken the following steps to ensure that modern slavery is not taking place within its organisation or supply chains:

· Embedding a zero-tolerance approach to modern slavery, servitude, forced labour, and human trafficking across all areas of the business.

· Implementing a Modern Slavery Policy which is communicated to all staff, applicants, and relevant stakeholders, setting out clear expectations and reporting procedures.

· Strengthening safer recruitment procedures, including identity checks, right to work verification, safeguarding checks, and confirmation of qualifications where appropriate.

· Reviewing supplier relationships and contracts to ensure that suppliers are expected to comply with all relevant legislation and ethical standards, with the right to terminate agreements should concerns arise regarding modern slavery.

· Assessing and monitoring supply chain risk, particularly in relation to third-party service providers such as payroll, IT systems, compliance services, and training organisations.

· Incorporating safeguarding and ethical considerations into procurement practices, ensuring suppliers are selected based on compliance, reputation, and alignment with our values.

· Maintaining whistleblowing and reporting procedures that allow employees, applicants, and stakeholders to raise concerns safely and confidentially.

· Providing staff training and awareness initiatives to ensure employees understand the risks of modern slavery and know how to identify and escalate concerns.

· Conducting regular policy reviews and updates to ensure ongoing compliance with the Modern Slavery Act 2015 and alignment with best practice guidance.

· Promoting ongoing monitoring and internal review processes to identify, assess, and mitigate any emerging risks within the business or supply chain.

Through these measures, Placing People Direct Ltd demonstrates its continued commitment to preventing modern slavery and ensuring that ethical standards are embedded across all aspects of its operations and partnerships.

MODERN SLAVERY COMPLIANCE OFFICER

The Placing People Direct Ltd has a Modern Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Founder and Director obligations in this regard. 

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval by:

Signed: Sunita Nahar – Founder and Director 

Date: 14th June 2026