Modern Slavery Policy

1. Policy statement

Luma Education Recruitment Ltd ("Luma") has a zero-tolerance approach to modern slavery, which includes slavery, servitude, forced or compulsory labour and human trafficking. We are committed to acting ethically and with integrity, and to complying with the Modern Slavery Act 2015.

As a recruitment business, we recognise that people can be exploited through the recruitment process itself, for example through fees, debt or third parties controlling a worker's pay. Our procedures are designed to prevent this.

2. Responsible recruitment

• No fees for work-seekers. We never charge candidates or workers a fee for finding them work, as the Employment Agencies Act 1973 and the Conduct Regulations require.
• Identity and right to work. We verify every candidate's identity and right to work in the UK before they start, in person or by video.
• Pay goes to the worker. Workers are paid directly into a bank account in their own name, through PAYE. We look into it if several workers share a bank account, address or phone number, or if a third party tries to manage a worker's registration or pay.
• Clear terms. Every worker receives written terms explaining their pay, hours and rights before they start, in plain English.
• Freedom to leave. Workers keep their own identity documents and are free to end an assignment or their registration at any time.

3. Signs we look out for

Our team is trained to notice possible signs of exploitation, including a candidate who:

• does not have their own identity documents or seems to be controlled by someone else;
• is accompanied to meetings by a person who answers for them;
• shares contact details or bank details with other candidates;
• seems frightened, withdrawn or unsure of their own address or employer;
• mentions owing money to someone who arranged their travel or work.

4. Supply chain

Our main suppliers provide software, payroll, vetting and professional services. We assess modern slavery risk when we choose a supplier, ask key suppliers to confirm they comply with the Modern Slavery Act, and include ethical labour clauses in our contracts. We will take action, which may include ending the relationship, if a supplier breaches this policy.

5. Reporting a concern

If you have any concern about modern slavery or exploitation, report it to:

• Daniel Benson, Director: daniel.benson@lumaedrec.com, 0204 576 4344
• Tom Jackson, Director: tom.jackson@lumaedrec.com, 0204 576 4102
• our confidential whistleblowing procedure

You can also call the Modern Slavery and Exploitation Helpline on 08000 121 700. If someone is in immediate danger, call 999. Nobody will suffer any detriment for raising a concern in good faith.

6. Training

Directors and staff complete modern slavery awareness training at induction and refresh it regularly, and know how to report a concern.

7. Responsibilities

The directors approve this policy and monitor how it is applied. Everyone working for Luma must follow it and report any concern.

8. Monitoring and review

We review this policy every year, together with our recruitment procedures and supplier checks, or sooner if our operations or the law change.

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