Modern Slavery and Human Trafficking Statement

1. Our commitment

Pickles Recruitment Ltd has zero tolerance for modern slavery, human trafficking, forced labour, servitude, debt bondage, child labour and exploitation. As a labour provider, we recognise that recruitment can be targeted by people seeking to exploit vulnerable workers. We therefore place worker welfare, lawful recruitment, transparent pay and robust identity checks at the centre of our operating model.

We are a GLAA licensed labour provider and an REC Corporate Member. We have also successfully completed a Fair Work Agency audit. These credentials support, but do not replace, our own continuing responsibility to identify risk, act on concerns and improve our controls.

2. Organisation, services and supply chain

Pickles Recruitment is an independent recruitment business based in Denton, Greater Manchester. We provide temporary and permanent recruitment services, with particular experience in food manufacturing, manufacturing, industrial, engineering and commercial recruitment. We place temporary and permanent people into work each year and supply hundreds of local workers each week.

• Our direct workforce includes recruitment consultants, administrators and management staff.

• Our labour supply chain includes temporary workers and candidates sourced directly, through referrals and through approved advertising channels.

• Our purchased goods and services may include technology, payroll, professional advice, office services, advertising and training.

• Our greatest inherent modern slavery risks arise in temporary labour supply, identity fraud, third-party control of workers, unlawful deductions, recruitment fees, coercion, transport or accommodation dependency and workers with limited English or limited knowledge of UK employment rights.

3. Governance and responsibility

4. Policies and standards

Our approach is supported by our Ethical Recruitment Policy, Labour Standards and Worker Welfare Policy, whistleblowing arrangements, grievance procedures, right-to-work process, equal opportunities commitments, data protection controls and supplier due diligence. We expect employees, workers, contractors and suppliers to act consistently with these standards.

5. Due diligence and prevention controls

1. Confirm identity and right to work using original documents or the Home Office online service, as applicable, and check that the person presenting matches the evidence.

2. Interview or speak directly with the worker wherever practicable. We do not rely solely on a third party who appears to control communication.

3. Issue clear written information about assignment, pay, deductions, holiday entitlement, working hours and how to raise concerns.

4. Never charge workers recruitment fees for finding or placing them in work.

5. Pay wages only through controlled payroll processes and investigate requests to pay unrelated third-party bank accounts.

6. Look for indicators such as multiple workers sharing unusual contact details or bank accounts, another person holding documents, fearfulness, scripted answers, unexplained transport or accommodation arrangements, excessive dependency, signs of debt or threats.

7. Assess client sites and assignments for suitability, working conditions, supervision, hours, health and safety and welfare arrangements.

8. Maintain accurate records and cooperate with lawful audits and investigations.

9. Review suppliers proportionately, with greater scrutiny where services could affect worker welfare or payroll integrity.

6. Risk assessment and remediation

Modern slavery risk is assessed by considering sector, role, location, recruitment channel, worker vulnerability, use of intermediaries, shift patterns, transport or accommodation dependency, payment arrangements and any intelligence received. Higher-risk indicators trigger enhanced checks and management review.

Where a concern is identified, our first priority is worker safety. We will avoid actions that could increase risk to the individual. We may pause an assignment or payment change, separate interviews, seek specialist advice, preserve documents, notify authorities and work with the client to remedy unsafe or unlawful conditions. We will not knowingly terminate or penalise a worker merely because they may be a victim of exploitation.

7. Training and awareness

Relevant staff receive induction and refresher guidance on modern slavery indicators, right-to-work checks, ethical recruitment, confidentiality, escalation and non-retaliation. Learning is reinforced through audit findings, compliance updates and case reviews. Managers are expected to challenge unusual patterns rather than treating onboarding as a box-ticking exercise.

8. Monitoring and objectives

Measure

1. Worker charges

2. Right-to-work compliance

3. Concerns and remediation

4. Training

5. Client and supplier due diligence

6. Annual review

Commitment

1. Target: zero recruitment fees charged to workers.

2. Target: 100% completed before work starts, subject to lawful verification routes.

3. Log, investigate and close concerns with management oversight; record learning and actions.

4. All relevant staff to receive induction and periodic refresher training.

5. Risk-based review of clients, assignments and critical suppliers.

6. Review this statement, risks, incidents and improvement plan at least annually.

9. Speaking up

Workers, employees, clients and suppliers are encouraged to report concerns to Julie Pickles, Managing Director, at julie@picklesrecruitment.co.uk or 0161 339 9595. Concerns may be raised confidentially. No person will suffer retaliation for raising a genuine concern in good faith.

10. Approval

This statement was approved by the Managing Director of Pickles Recruitment Ltd on 5 August 2026 and will be reviewed annually.

Reference framework

Modern Slavery Act 2015, section 54; Home Office Transparency in Supply Chains guidance; GLAA Licensing Standards; REC Code of Professional Practice; Sedex/SMETA labour standards principles.