Modern Slavery Statement

Reporting Period: Financial Year Ended 31 January 2025
Publication and Review Date: 1st February 2026

1. Our Commitment

Placing People Direct Ltd is committed to conducting its business ethically, responsibly and with integrity. We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude and exploitation within our own operations and throughout the organisations and suppliers with whom we work.

Placing People Direct Ltd has an annual turnover significantly below the £36 million threshold at which organisations are required to publish an annual modern slavery statement under section 54 of the Modern Slavery Act 2015.

We have nevertheless chosen to publish this statement voluntarily as part of our commitment to ethical recruitment, safeguarding, transparency and responsible business practices.

This statement has been prepared with reference to the principles and recommended reporting areas set out in section 54 of the Modern Slavery Act 2015 and associated Government guidance. It describes our approach to identifying, preventing and mitigating the risks of modern slavery within our operations and supply chain.

2. About Placing People Direct Ltd

Placing People Direct Ltd is an independent recruitment and employment-support organisation specialising primarily in the education, early years, childcare and related sectors.

We work with nurseries, schools, colleges, local authorities, training providers and other organisations across England to support the recruitment and placement of suitably qualified individuals into employment opportunities.

Company: Placing People Direct Ltd
Company Registration Number: 12391127
Registered Office: Kemp House, 160 City Road, London, England, EC1V 2NX

Responsibility for the Company’s approach to modern slavery rests with the Director.

3. Our Operations and Supply Chain

Our activities involve applicants seeking employment, client organisations seeking to recruit staff, and suppliers and professional partners that support the delivery of our recruitment and employment-support services.

Our direct operations are predominantly UK-based and our supply chain is relatively straightforward.

Our suppliers and professional partners may include organisations providing:

training and employment-support services;
payroll and financial services;
recruitment and compliance services;
safeguarding and background-check services;
insurance and professional services;
IT, software, website and hosting services; and
other administrative and business-support services.

We recognise that some of our direct suppliers may themselves use subcontractors or other suppliers. Although we do not necessarily have a direct contractual relationship with these organisations, we expect those with whom we do business to operate ethically and comply with applicable employment, labour and human rights legislation.

Applicants are not treated as part of our supply chain. However, because recruitment and employment are central to our activities, protecting individuals seeking work from exploitation, coercion and unethical recruitment practices is an important part of our approach to preventing modern slavery.

4. Our Policies

Placing People Direct Ltd maintains policies and procedures intended to support ethical business practices, safer recruitment, safeguarding and the prevention of exploitation.

Relevant policies and procedures include, where applicable:

Modern Slavery Policy;
Safer Recruitment and Recruitment Policy;
Safeguarding and Child Protection Policy;
Equality, Diversity and Inclusion Policy;
Whistleblowing Policy;
Anti-Bribery and Corruption Policy;
Data Protection and Confidentiality Policy;
Corporate Social Responsibility and Social Value Policy; and
Supplier and Partner Code of Conduct.

These policies support our commitment to treating applicants, employees, clients, suppliers and other stakeholders fairly, ethically and with dignity and respect.

Relevant policies are reviewed periodically to ensure that they remain appropriate to our operations and reflect applicable legislation and good practice.

Copies of relevant policies are available from Placing People Direct Ltd upon request.

5. Assessing Modern Slavery Risk

We consider the overall risk of modern slavery occurring within our direct operations to be relatively low because of the nature, scale and predominantly UK-based nature of our business.

However, we recognise that no organisation or supply chain is entirely free from risk.

As a recruitment business, we recognise that people seeking employment can, in some circumstances, be vulnerable to exploitation. Potential areas of risk include:

applicants who may be vulnerable because of language barriers, financial hardship or limited understanding of their employment rights;
individuals whose immigration or right-to-work status may increase their vulnerability to exploitation;
applicants who are dependent upon third parties for accommodation, transport or employment arrangements;
international applicants and the verification of overseas qualifications and documentation;
third-party suppliers and service providers where we have limited visibility of their own employment practices or lower-tier supply chains; and
subcontracted or outsourced services.

We remain alert to potential indicators of forced labour, debt bondage, coercion, trafficking, restriction of movement, withholding of documents or wages, and other forms of exploitation.

Our assessment of risk is proportionate to the size and nature of our business and is reviewed as our operations, partnerships and supply chain develop.

6. Due Diligence and Safeguards

We take proportionate steps to reduce the risk of modern slavery and exploitation within our recruitment activities and business relationships.

These include:

undertaking appropriate identity and right-to-work checks;
carrying out safer recruitment and safeguarding checks relevant to the roles for which we recruit;
verifying qualifications and documentation where appropriate;
seeking to ensure applicants understand the nature and terms of employment opportunities presented to them;
working with reputable clients, suppliers, training organisations and professional partners;
considering ethical, safeguarding and compliance standards when establishing business relationships;
expecting suppliers and partners to comply with applicable employment and human rights legislation;
remaining alert to circumstances that may indicate exploitation, coercion or unethical recruitment practices; and
providing mechanisms through which concerns can be reported and appropriately escalated.

Where concerns regarding modern slavery or exploitation arise, we will assess the circumstances and take appropriate action. This may include seeking further information, escalating safeguarding concerns, reviewing or terminating a business relationship where appropriate, and referring matters to the relevant authorities where necessary.

We will not knowingly conduct business with an organisation that engages in, supports or facilitates modern slavery, human trafficking or forced labour.

7. Protecting Applicants

Applicant welfare is particularly important to us because of our role within recruitment and employment support.

We seek to ensure that individuals using our services:

are treated fairly and with dignity and respect;
understand the employment opportunities for which they are being considered;
are not subjected to coercion or exploitative recruitment practices;
have their identity and right-to-work documentation handled appropriately;
are not discriminated against because of vulnerability or personal circumstances; and
are able to raise concerns about employment practices, safeguarding or potential exploitation.

Any concern suggesting that an individual may be experiencing exploitation, trafficking, forced labour or another safeguarding risk will be treated seriously and escalated as appropriate.

8. Training and Awareness

We recognise that awareness is an important part of preventing modern slavery.

Employees and associates involved in recruitment and applicant engagement are made aware, as appropriate to their roles, of the importance of:

safer recruitment and safeguarding;
ethical recruitment practices;
identity and right-to-work verification;
recognising potential indicators of exploitation or coercion;
treating applicants fairly and with dignity; and
reporting and escalating concerns.

Our aim is to ensure that individuals involved in recruitment activities understand that concerns relating to modern slavery, exploitation or unethical practices should not be ignored and know how they can be raised.

Training and awareness arrangements are reviewed periodically and may be strengthened where changes in legislation, guidance, our activities or identified risks indicate that additional measures would be appropriate.

9. Reporting Concerns

Employees, applicants, clients, suppliers and other stakeholders are encouraged to raise concerns relating to suspected modern slavery, human trafficking, forced labour, exploitation or unethical employment practices.

Concerns may be raised through our Whistleblowing Procedure or directly with the Director of Placing People Direct Ltd.

Concerns will be treated seriously and handled as sensitively and confidentially as reasonably possible. No person raising a genuine concern in good faith should be subjected to detrimental treatment for doing so.

Where appropriate, concerns may be referred to relevant safeguarding bodies, law-enforcement agencies or other competent authorities.

10. Monitoring and Effectiveness

As a small organisation, we take a proportionate approach to monitoring the effectiveness of our modern slavery controls.

Our measures include:

maintaining awareness of modern slavery risks within our recruitment activities;
monitoring compliance with relevant safer recruitment, identity and right-to-work procedures;
reviewing concerns, complaints, safeguarding matters or allegations that could indicate exploitation;
reviewing relevant supplier and partner relationships where risks are identified;
maintaining appropriate reporting and escalation procedures; and
reviewing this statement and associated policies periodically.

We seek to monitor our effectiveness through measures including:

ensuring relevant employees and associates are made aware of our approach to modern slavery and the procedures for raising concerns;
ensuring concerns relating to potential modern slavery or exploitation are appropriately recorded, assessed and addressed;
reviewing identified higher-risk supplier or partner relationships where appropriate;
monitoring the consistent application of relevant recruitment and compliance procedures; and
reviewing our Modern Slavery Statement and associated policies at least annually.

We will use any concerns, incidents or identified weaknesses to inform improvements to our procedures.

11. Actions and Continuing Improvement

During the reporting period and as part of our continuing approach to responsible recruitment, Placing People Direct Ltd has maintained a zero-tolerance approach to modern slavery and exploitation and has incorporated safeguarding, safer recruitment and ethical considerations into its recruitment activities.

Our continuing priorities are to:

maintain effective safer recruitment and compliance procedures;
remain alert to emerging modern slavery risks affecting recruitment and employment;
maintain appropriate mechanisms for reporting and escalating concerns;
consider modern slavery and ethical standards when working with suppliers and partners;
maintain staff awareness appropriate to their roles; and
review our policies and procedures as our business and supply chain develop.

We recognise that preventing modern slavery is an ongoing responsibility. Our approach will continue to develop proportionately in response to changes in our operations, supply chain, legislation, Government guidance and identified risks.

12. Approval and Review

This statement relates to the financial year ended 31 January 2025.

Placing People Direct Ltd is not required to publish a modern slavery statement under section 54 of the Modern Slavery Act 2015 because its annual turnover is below the statutory threshold. This statement has therefore been produced and published voluntarily.

It will be reviewed at least annually and updated where appropriate to reflect changes in our activities, risks, policies and procedures.

Approval

This Modern Slavery Statement was approved by the Director of Placing People Direct Ltd on 1st February 2026 and is signed on behalf of the Company by:

Sunita Nahar
Founder and Director
Placing People Direct Ltd

Date: 1st February 2026