Previous Year's statements: Financial Year End 31st March 2020 | Financial Year End 31st March 2021 | Financial Year End 31st March 2022

MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT

This Modern Slavery and Human Trafficking statement, published in accordance with section 54 of the Modern Slavery Act 2015, sets out the steps that WK1 Limited (‘WK1’) has taken during the year ending 31 March 2022 to help prevent modern slavery in our operations and supply chain.

Organisation structure and supply chains

WK1 was incorporated in June 2017 and began trading in January 2019. WK1 is a contracting intermediary, supplying temporary labour to a mixture of agency and end user clients and so, during the year ending 31 March 2022, WK1’s staff undertook registrations of the temporary workforce, liaising with clients, undertaking business development, operating weekly payroll and meeting its obligations under the Construction Industry Scheme (‘CIS’).

The temporary labour supply is provided to a number of industries such as construction, packaging, industrial, warehousingand transport – WK1 does not seek to specialise in a particular industry sector. In this regard, there is no industry that WK1 focus on in terms of mitigating risk of modern slavery – WK1 ensure that all aspects of its operations and all industries are considered. For the avoidance of doubt, WK1 do not operate in GLAA licensed sectors.

Policies in relation to slavery and human trafficking

Whilst preventative measures were already in place, WK1 has been implementing further processes and procedures since the 2019/20 financial year when WK1 met the £36m threshold to require a Modern Slavery and Human Trafficking Statement.

Due diligence processes

WK1 undertake initial due diligence on all of labour providers, as well as conducting ongoing reviews throughout their engagement to mitigate the risk of worker exploitation, human trafficking or modern slavery taking place in their labour supply chains (as well as reviewing other aspects of compliance).

WK1 are sometimes asked to complete clients’ or potential clients’ due diligence processes or questionnaires to enable them to be on a client’s Preferred Supplier List (‘PSL’) – this may include questions on modern slavery compliance and ethical supply chains. WK1 work cooperatively with its clients (and labour suppliers) and openly discuss its approach to modern slavery.

WK1 will not knowingly engage with any business involved in modern slavery. In the event that WK1 became aware of any modern slavery issues within any aspect of our operations, this would be escalated to a Director of WK1 and appropriate action will be taken, depending on the circumstances. This could range from communicating with our clients/labour suppliers, making positive changes, seeking advice/reporting the incident to the appropriate authorities, to terminating relationships.

Whilst WK1 does not operate in GLAA licensed sectors, WK1 works with Aspire Business Partnership whose Senior Managers hold a Certificate in Investigating Modern Slavery, awarded by the Gangmasters Licensing Authority in partnership with the University of Derby.

Risk assessment and management

WK1 believe areas that represent higher risk include;

• Workers who have difficulties speaking English requesting that WK1 registration staff speak to another person with better English – WK1 ensure that the worker answers particular questions themselves initially and that proper permission is sought prior to discussions beginning with the other person. Calls may be recorded for monitoring and training purposes.
• Duplicate bank details provided – WK1 regularly undertake checks to monitor this. Where this occurs WK1’s staff will query why two people have provided details for the same account and ensure the response is satisfactory and is recorded.
• Lower paid workers paid at or around the National Minimum Wage (NMW) or National Living Wage (NLW) – checks against employees’ date of birth are undertaken to ensure NMW/NLW is not breached. WK1 undertake due diligence to ensure its labour suppliers do not breach the minimum wage.
• WK1 may outsource the supply of labour to third-party labour suppliers – due diligence is undertaken and further information on this process has been explained above.
• Right to Work checks are undertaken on WK1’s employees in accordance with the Home Office guidance. WK1 undertake due diligence to ensure its labour suppliers also conduct these checks and have corresponded with suppliers and clients during the year ending 31 March 2022 regarding the changes Right to Work to ensure compliance with the new processes.

Key performance indicators to measure effectiveness of steps being taken

In the year ending 31 March 2022 WK1 has had no correspondence from its clients, labour suppliers, workers, or the GLAA or any other party, in relation to slavery and human trafficking in its supply chain.

Training on modern slavery and human trafficking

WK1 are committed to staff training and so, all staff undertake online training courses on areas such as payroll and GDPR.

Regular meetings are held internally between the director(s) of WK1 and the staff to discuss key updates in the temporary labour industry.

A training event conducted by Aspire Business Partnership was attended by some of WK1’s staff in August 2021 and the training included an update in relation to the Modern Slavery Act 2015, due diligence in labour supply chains and Right to Work obligations.

Lee Sargeant
Director
March 2022