Modern Slavery Policy

Introduction

Eleo Talent Ltd (“Eleo”) is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. We impose the same high standards on our suppliers. This policy outlines our approach to tackling modern slavery in compliance with the Modern Slavery Act 2015.

Our Commitment

Eleo has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Our Business and Supply Chain

As a recruitment agency specialising in the healthcare sector, our business primarily involves connecting skilled professionals with healthcare organisations. Our supply chain includes various service providers that support our operations.

Due Diligence Processes

Eleo undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. This includes:

  1. Mapping the supply chain to assess particular product or geographical risks of modern slavery and human trafficking;
  2. Evaluating the modern slavery and human trafficking risks of each new supplier;
  3. Conducting supplier audits or assessments which have a greater focus on slavery and human trafficking where general risks are identified;
  4. Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Risk Assessment and Management

Eleo regularly assesses the risk of modern slavery occurring in our operations and supply chain. We have implemented the following measures to manage this risk:

  1. Training staff on modern slavery issues and how to identify and report concerns;
  2. Encouraging open communication with suppliers about our anti-slavery policy;
  3. Ensuring our recruitment processes are transparent and reviewed regularly;
  4. Implementing robust policies and procedures to ensure compliance with labour laws.

Training and Awareness

We provide training to our staff on modern slavery issues, ensuring they understand:

  1. The basic principles of the Modern Slavery Act 2015;
  2. How to identify and report potential cases of modern slavery;
  3. The steps Eleo has taken to tackle modern slavery.

Our Effectiveness in Combating Modern Slavery

We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

  1. Staff training levels;
  2. Actions taken to strengthen supply chain auditing and verification;
  3. Steps taken to upskill high-risk suppliers;
  4. Investigations undertaken into suspected instances of modern slavery.

Reporting Concerns

We encourage all our employees, customers, and suppliers to report any suspicion of modern slavery in any part of our business or supply chain. We provide a safe and confidential means to do so.

Responsibility for the Policy

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Policy Review

This policy is reviewed annually by our board of directors and may be amended from time to time.

This Modern Slavery Policy was approved by the Board of Eleo Talent Ltd on 26 August 2024.