Modern Slavery Statement.

Our Group Code of Professional Conduct (Code) outlines our core principles to act ethically and with integrity in all our business dealings and relationships. All employees are expected to adhere to the Code and its underlying principles. Specifically in reference to slavery and human trafficking, the Code sets out our commitment to implement, enforce and monitor effective systems and controls to ensure that neither slavery nor human trafficking is taking place anywhere in our business or in any of our supply chains.  

Our Group Modern Slavery Policy addresses in further detail the responsibilities of all employees to prevent, detect and report any concerns of modern slavery or human trafficking in any part of our business or supply chain throughout their business dealings. This Policy also reflects our commitment to ensuring that any detrimental treatment toward an individual for speaking up about concerns of modern slavery or human trafficking is not tolerated. 

Our Speak Up Policy confirms this commitment and provides a vehicle to enable employees to voice any concerns in a responsible and effective manner. Any concerns raised are initially reviewed by a defined cohort of employees across the People, Compliance and Legal teams who will define the best course of action to effectively address the concern. 

Our Supplier Code of Conduct sets out our ethical standpoints, and inherently what we expect from our suppliers too, both in principal and in spirit. Our expectation is for this to cascade through our suppliers’ supply chains as well to maximise the best opportunity of ethical reach.  

Our Sustainability Report is a culmination of all our efforts around our ESG agenda which includes operating with fair and ethical conduct.  

We have effective systems in place to investigate any concerns raised in line with any of these policies, and keep them under regular review for relevant updates. We continue to review the effectiveness of our internal controls via our enterprise Risk Assurance programme and regular Group Compliance reporting.  

Gattaca’s Supply Chains  

Our supply chain is comprised of suppliers who provide goods and services to the Group, as well as those who are involved in the services we provide to our candidates and clients. This includes other recruitment agencies, workers who provide services via limited companies or as a self-employed consultant and payroll management or umbrella companies which are higher risk suppliers. 

We have a zero-tolerance approach to modern slavery and human trafficking in our business and our supply chain. The Group, primarily through or with oversight from the Executive and subject matter experts within the Group, periodically review our key suppliers (which includes insurance companies, financial service providers, recruitment agencies, payroll management and umbrella companies and workers). We will not work with any supplier organsiation that has been found to have knowingly been involved in modern slavery or human trafficking. 

As part of our contracting processes we include specific prohibitions against any form of modern slavery or human trafficking. We expect our suppliers to adhere to the same high standards and take steps to ensure this approach is reflected in their supply chains. 

Due diligence in the supply chain 

For suppliers to our UK business we have a Supplier Onboarding Process, whereby suppliers receive our Supplier Code of Conduct which they are expected to adhere to.  This involves a commitment to acting ethically and with integrity at all times, and ensuring effective controls are in place to prevent modern slavery or human trafficking from taking place both in their business and within their supply chains. Our international offices are able to utilise the structure and intent of this process to manage their procurement locally.  

We categorise our UK suppliers according to the nature and volume of their service, and tailor due diligence and compliance processes accordingly. This includes an annual review process of this compliance documentation. 

For high-risk suppliers (such as those providing payroll services), we conduct thorough due diligence, following which each supplier must be approved prior to any entity in the Group engaging in any business with them. Each of these suppliers is required to enter into appropriate contractual obligations, which include the right to audit by Gattaca, and the requirement to comply with ongoing compliance monitoring and further due diligence requests.  Our processes apply a number of controls to ensure that only approved suppliers are utilised, and then apply a programme of periodic review for each supplier. 

Risk assessing our business 

The nature of our business is to fulfil outsourced staffing solutions and recruitment services by supplying workers to clients. At the point of taking a vacancy and at fulfilling that vacancy, we operate a placement risk check process. This enables us to identify any high-risk countries, ensuring that we don’t support any business in such locations.  

Gattaca undertakes a number of rigorous checks on each individual including eligibility to work in accordance with Home Office requirements, references, qualifications, proof of NI (UK), and bank details to ensure each person is acting in their own right and are getting access to their own pay. We ensure that at least National Minimum Wage is paid to all employees and contractors. 

Where safety could be a particular concern due to the nature of the role or the working environment, clients are asked a series of qualifying questions to ensure the safety of workers in the environment in which we are sending them to work. Any information is monitored by the Health & Safety department, and followed up, as necessary, with appropriate action. 

We maintain contact with workers throughout temporary or contract assignments to ensure the integrity of the placement and the safety of the worker. 

Specific and appropriate steps are taken to mitigate higher risk placements. As an example, we are licensed with the Gangmasters Labour and Abuse Authority (GLAA) with regard to any placements that fall under this requirement, and we are a member of the Railway Industry Supplier Qualification Scheme (RISQS) which verified that we operate as an ethical business, to supply into a high-risk environment.  We successfully maintain a suite of ISO certifications that demonstrate the integrity of our business and the quality of our operations, namely ISO 9001:2015 Quality Management and ISO 45001:2018.