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 2021 to help prevent modern slavery in our operations and supply chain.

WK1 was incorporated in June 2017 and began trading in January 2019. With offices in Felsted, Essex, WK1 is a contracting intermediary, supplying temporary labour to a mixture of agency and end user clients. WK1 has staff working from its Felsted office undertaking 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, warehousing, hospitality and 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.

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. During the upcoming financial year WK1 intends to continue implementing steps to mitigate any risk of modern slavery and worker exploitation in its operations and supply chain.

WK1 believe areas that represent higher risk include;

• Foreign 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. All calls are recorded.
• 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.
• WK1 may outsource the supply of temporary labour to third-party labour suppliers – WK1 undertake initial due diligence on all of their 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).
• 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.
• Limited companies engaging their own workforce - WK1 has taken the commercial decision to no longer engage Limited Companies, effective from the beginning of the 2021/22 tax year.This will reduce the risk of modern slavery occurring via the engagement of labour via ‘gangmasters’.
• 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. Our checks will be updated in accordance with the new guidance to dictate checks post July 2021.

WK1 are committed to staff training and so, all staff undertake online training courses on areas such as payroll and GDPR. In the next financial year WK1 will seek to increase staff awareness on modern slavery. One of the resources utilised will be the use of the GLAA awareness videos on labour exploitation and modern slavery, which can be found on YouTube

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.

Lee Sargeant
Director
March 2021