Organisation: Be Personnel Ltd

Site: All

Country/Sector: UK all sectors (except construction)

Partner Type: Advanced

Business Type: Small business | Individual site | UK Labour Provider

Company Sedex registration number (ZC):

Site Sedex registration number (ZS): ZC1006718

N.B. Click submit at the bottom once all files are ready to be uploaded. Allowed document formats (PDF, DOC, DOCX, PPT, PPTX, JPG).

Business Partner Advanced Commitments
Evidence of Implementation
1. A senior manager has attended all of the following Stronger Together training workshops in the last three years:
  • Advanced Tackling Modern Slavery in UK Businesses
Claire Cookson
Managing Director
2. The business has developed, implemented, and annually reviews a policy on:
  • Hidden Labour Exploitation

The title of this policy may differ per business, e.g. for technical, contextual or legislative reasons.

Upload your policy.
3. A senior manager has been appointed with overall responsibility for implementing the business Hidden Labour Exploitation Policy in our operations and supply chain.
Claire Cookson
Managing Director
4. The site has implemented at least 70% of Stronger Together’s:
  • Employer Good Practice Implementation Checklist
  • Labour Provider Implementation Interactive Checklist

Checklists available to download here

Please note only checklists completed within the last three months are valid

Upload copy of the recently completed Checklist.
Upload copy of the recently completed Summary Report.
5. An established ongoing management system and training programme is in place to ensure key staff are aware of their responsibilities to address Hidden Labour Exploitation risks, including how to spot the signs of forced labour and hidden labour exploitation at work and how to act appropriately where these have been identified. Key staff can include:
  • Members of the senior management team
  • Supervisors and team managers
  • HR, Payroll and staff involved in direct recruitment
  • Worker and Trade Union representatives
  • Recruitment intermediaries
  • Sub-contracted Labour Providers

All Be Personnel employees are provided with Stronger Together training whether this be online or workshop based, along with regular updates and and coaching from the Managing Director and/or their appropriate Line Manager. Consultants sign the Stronger Together Recruiter Compliance Principles ahead of interviewing any applicants and this document is held within their personnel file. Claire Cookson, Managing Director, is responsible for executing and overseeing all processes and policies to prevent and mitigate modern slavery and forced labour.
6. You implement ongoing awareness raising and engagement activities with workers. This can include:
  • Displaying the Stronger Together workplace posters
  • Issuing Stronger Together worker leaflets to all workers (including any temporary, seasonal and contractor workers via the labour provider/recruitment intermediary/service provider)
  • Delivering training sessions
  • Promoting grievance and whistleblowing channels that are available to report concerns
  • Appointing a Stronger Together/Modern Slavery Champion to promote reporting channels and the signs of labour exploitation
  • Conducting team briefings
  • Promoting the Just Good Work App with workers
  • Conducting worker welfare interviews
  • Collaborating with Trade Union representatives to engage workers
  • Inviting local support services/charities to speak to workers
Upload photo evidence

Be Personnel displays the Stronger Together workplace posters within our offices and also issues the leaflets to all workers. Training is delivered at induction for workers and all relevant policies are made available.
7. A session on Hidden Labour Exploitation is incorporated into inductions for new workers, including any temporary, seasonal and contractor workers. Induction content may include one of the following:
  • Awareness videos:
    Daniel and Weronika
    Know Your Rights in the UK
  • Awareness posters and leaflets
  • Share information on how to download Just Good Work
Upload evidence of induction content.

Hidden Labour Exploitation is included within the induction by means of the Daniel & Weronika video being viewed along with the Stronger Together Worker leaflets being provided and confirmation as to where any concerns should be reported to. The Stronger Together worker questionnaire is also completed at this stage.
8. You have engaged with all your labour providers, recruitment intermediaries and subcontractors to require that they:
  • Register with Stronger Together
  • Attend a Stronger Together training workshop, and
  • Are effectively implementing the Stronger Good Practice Implementation Checklist
9. You regularly conduct pro-active checks for indicators of exploitation. These checks could include any of the following:

- Worker records checks including:

  • Multiple use of the same addresses, indicating multiple/high occupancy
  • Bank accounts to identify unrelated workers paid into one account or accounts with sequential account numbers
  • Shared Mobile phone numbers in contact details
  • Documents for the shared next of kin/emergency contact details
  • Multiple application forms completed in the same handwriting
  • Landlord information to verify if a staff member is providing accommodation
  • Conditions of Employment include freedom of choice; not paying recruitment fees, etc.

- Making workers aware of conditions of employment prior to taking up work
- Using and maintaining a Grievance Mechanism to pick up on worker issues


From inception of the interview process, Consultants and Resourcers check for signs of forced labour and hidden labour exploitation both visually as well as through effective use of questioning. A Stronger Together worker questionnaire is completed with all new starters to gather information on how they came to hear about Be Personnel and the vacancy, check that no recruitment fees have been paid and that their accommodation is not provided by a staff member. Be Personnel's Administrative and Payroll function conduct secondary reviews of new starter documentation upon this being uploaded to our internal CRM in order to spot any signs of concern including but not limited to, duplicate telephone numbers, addresses, next of kin and bank accounts. Monthly audits are then conducted from payroll data to monitor these areas.
10. The business has established how it will respond where a potential case of Hidden Labour Exploitation is identified, whether with directly employed staff, agency workers or on-site contractors. Any such reports are acted on appropriately.

Where a concern has been raised regarding a potential case of Hidden Labour Exploitation all staff are trained to report this to their Line Manager and Managing Director for initial review. Be Personnel will seek advice as appropriate via our Modern Slavery Consultant and report all information in relation to the concern directly to the GLAA.
11. The business is committed to share reports detailing the actions taken to address Hidden Labour Exploitation risks, disclosing externally an annual statement detailing the actions taken. The statement accords with legislative requirements and Stronger Together good practice guidance.
Upload copy of the statement.


12. The business receives updates on issues and developments with regards to addressing the risks of Hidden Labour Exploitation. Examples include:

Be Personnel receives regular updates via email and through social media groups from Stronger Together as well as other third parties including the Association of Labour Providers, REC and the GLAA.