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This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the
“Act”) and sets out the approach which Atlas Professionals BV, NextWave Partners PTE
Limited, and their affiliates (together “Atlas Group”, “Our” or “We”) have taken to
understand potential modern slavery risks related to our business and the actions
undertaken to mitigate any such risks during the financial year ending 31 December
2023.
Our Vision is ‘To help shape the sustainable future of the clean-tech, energy, infrastructure, and marine markets, by delivering creative people solutions and supporting our customer, colleague, and candidate community to make a meaningful impact on our planet’s journey to net zero by 2050.’
We are great at recruitment, but we are so much more. From boardroom to site, land to sea, hardware to software, in local, global, and emerging markets, we are our clients' knowledge partner, helping to solve complex staffing challenges through our team of multi-discipline experts.
The Atlas Group specialises in partnering with our global clients to provide full-service
staffing and workforce solutions across the Clean-Tech, Marine, and Energy sectors to a
wide range of clients. Our business has a global reach, and we are dedicated to ethical
practices and processes within every aspect of the business.
Our staffing and workforce solutions are provided on the basis of compliance, integrity, and responsibility and in accordance with applicable local and international laws. We understand our legal and moral obligation to prevent slavery and human trafficking within our business and the supply chains through which it operates.
We seek to provide a working environment that is free from harassment and disrespectful conduct. We will not use child labour, we provide equal opportunities, and we do not discriminate based on gender, race, religion, age, disability, nationality, social, or ethnic origin.
We recognise our responsibility to respect human rights in all aspects of doing business and have embedded human rights in our Code of Conduct and internal policies, including the Health, Safety, and Environmental (HSE) policy and Whistleblower policy, and within our supply chain management process.
Our policies cover, among others, freedom of association and the effective recognition of the right to collective bargaining and the prohibition of forced or compulsory labour. Additionally, our policies include principles to ensure that our ethics and human rights standards are upheld.
We believe that an integrated approach to human rights, by embedding it into our policies, business systems, processes, and culture, allows us to manage human rights effectively within our existing ways of working. Our policies apply to all our employees, personnel, and contractors.
Our main supply chain includes clients, business partners, and suppliers of services involved in the supply of workforce and staffing solutions and includes employers of record, financial, tax, payroll, immigration, logistics, and legal specialists and/or organisations, and suppliers of commodities, including utilities.
We understand that risks can occur throughout the supply chain, specifically in relation to suppliers of personnel, where extra due diligence is carried out to ensure no forced labour, trafficking, and deceptive recruitment practices are taking place.
We recognise the role of due diligence in bringing our commitments to life.
To ensure that partners and suppliers comply with applicable laws and regulations, we carry out due diligence assessments and verifications (part of an Integrated Management System which is audited yearly under Atlas Professionals’ ISO accreditation), which are reviewed by the relevant internal stakeholders.
It should be noted that in the UK, (like many other jurisdictions), labour supply chain due diligence is also a requirement for any business that uses, supplies, or makes arrangements to supply labour. Clear guidelines are available in the public domain, and we are required to adhere to these guidelines. We apply the same guidelines across the Atlas Group.
Atlas’ UK, Dutch, and German policies, processes, and procedures are regularly audited by external bodies, for example, the Employment Agency Standards Inspectorate (“ESA”) during 2023, against the SNA Standards every 6 months (a full audit and short inspection every year), and the AUG licensing body to renew our licence annually.
The regulations and audit process vary, but the purpose is universal for these jurisdictions and many others to ensure that the candidates, clients, and contractors are protected according to the relevant legislation. This is executed via several touch points through the process and is required to be consistent from one employment business to another in each jurisdiction.
Detailed sampling is undertaken by the relevant authority over the course of one/two days, usually on-site, and interviews with relevant staff members take place to ensure understanding of policy and process.
Our standard terms and conditions under which we operate require clients, suppliers, and contractors to comply with applicable laws and regulations, and there is specific focus on providing and maintaining safe and healthy working conditions for all personnel.
In addition to official policies and procedures, we would also consider termination of a contract if serious or persistent shortcomings are found. However, it should be noted that the only cause for contracts to be severed in the last 10 years has been in relation to sanctions in connection with Russia.
We have in-house specialists consisting of representatives with tax, law, immigration, insurance, licensing, audit, health and safety, quality, and general compliance expertise to review any highlighted potential non-compliance. The head of the Tax, Legal, and Compliance team reports directly to the CEO to ensure compliance is at the forefront of Our business.
If a violation is confirmed, we take appropriate action up to and including contract termination or dismissal. We maintain a stringent, no-retaliation policy to protect any person making a good faith allegation.
In addition, we regularly share updates and reminders to increase awareness of HSE, ESG, and labour rights topics, communicate our expectations, work to jointly identify any gaps and improvement opportunities, and promote best practices.
All staff have access to relevant policies and procedures and are actively reminded and required to confirm their understanding of such on an annual basis.
A selection of staff, with specific exposure to certain risks or areas, are also required to sign a compliance statement declaring that they are not aware of, nor have they been involved in, non-compliance of any description annually. A record of annual statements of understanding and authorised compliance statements is retained within the statutory timeframes.
In summary, we use the following key performance indicators (KPIs) to ensure that slavery and human trafficking are not taking place in any part of our business or supply chains:
We are committed to continually improving the quality of our operations. The long-term success of our business relies on our ability to ensure the health, safety, and well-being of our employees, contractors, and the public, as well as minimising our impact on the environment. Atlas Group requires compliance with the laws and regulations applicable to our business.
We have assessed the Atlas Group business and supply chain, our vision, mission, and policies, and the implemented processes and conclude that there is a low risk of slavery and human trafficking within the Atlas Group business. However, we commit to ongoing review to prevent slavery and human trafficking in our activities and supply chain.
This Statement is approved by the board of the Atlas Group on 30 May 2024 and signed on its behalf by Neil Tregarthen, CEO – Atlas Group.
Neil Tregarthen
CEO – Atlas Group