Hidden labour exploitation policy statement

Hidden labour exploitation is the exploitation of job applicants or workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims, if they perceive of themselves as such, reluctant to come forward.


This policy applies to all locations within Accept Recruitment.


Branches/ On sites will take responsibility for ensuring this policy is held in each branch/ on site process. Managers should take responsibility to ensure the policy is followed. Consultants must also implement it into their approach. This policy will be reviewed annually or more often as and when necessary.

Policy Commitments

Accept Recruitment shall:

  • Accept Recruitment has responsibility along with HR for developing and operating company procedures relevant to this issue.
  • Job finding fees are a business cost paid by clients. We will not allow these to be paid by job applicants. The Company will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
  • Ensure that all staff responsible for directly recruiting workers are aware of issues around third party labour exploitation and signs to look for.
  • Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent employees.
  • Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Licensing Authority and police.
  • Provide information on tackling “Hidden Labour Exploitation” to our workforce. Along with visible posters in the workplace displaying helplines.
  • Encourage workers to report cases of hidden third party labour exploitation. Provide the means to do so and investigate and act on reports appropriately.
  • Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities. Provide posters will helpline numbers


  • All staff have to make sure that when registering a candidate and conducting RTW checks, candidate is asked to provide their own bank account
  • Bank Details spot checks followed by weekly audit of Bank Details report – Managers
  • Weekly CRM system audit done by payroll team

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