Humlys statement on modern slavery

Humly’s statement on Modern Slavery

At Humly we are committed to improving our practices to combat slavery and human trafficking. We recognise that slavery and human trafficking is a real yet hidden issue in our society. This statement has been published in accordance with the Modern Slavery Act 2015

Humly will not tolerate slavery and human trafficking in our business or supply chain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that any form of slavery is not taking place in our own business or supply chain.

As a new company in the UK, this is a living document and will continue to be improved and added to as we continue to develop our policies in this area. 

This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business and to implement steps to prevent slavery and human trafficking during the financial year 2020/21.

Our business, employees and supply chains

Humly recruits supply teachers, cover supervisors and teaching assistant to fill temporary staff shortages in schools. 

We use reputable job sites to identify candidates for the positions and then interview them. These include Guardian Jobs, Indeed Jobs and University job boards. 

We check their identification documents and ask that their ID document is certified following the guidelines set out by the UK government here: https://www.gov.uk/certifying-a-document

We work almost exclusively with schools in the public sector and secure temporary positions at those schools for the supply teacher, cover supervisors and teaching assistants who are part of Humly.

All of our contractors are employed through an Umbrella Company Key Portfolio (KPPES Ltd.) who have a great deal of experience in providing employment services and have their own modern slavery statement which you can find here: https://keyportfolio.co.com/modern-slavery-statement

We have met with them on multiple occasions and performed due diligence before agreeing to work with them. They do their own right to work checks which complement our ID and DBS checks.

In terms of our payment process, we always ensure that no one employed by Humly is paid anything less than the national living wage. Anyone who wants to stop working with Humly can simply stop using the app and ask us to remove them from the platform.

We carry out due diligence checks on new suppliers and expect all suppliers to share our zero-tolerance approach to Modern Slavery and would not do business with any organisation who we had reason to believe was involved in it.

Risk Assessment:

We feel that the risk of modern slavery in our work is low because we conduct several checks on the people and companies that work with us, we work mainly with government-run schools who have robust procedures in place. 

We include as much information as we can in our training procedure so employees can recognise the signs of modern slavery.

We also have a complaints and concerns procedure that allows people to report any modern slavery related issues they see with the knowledge any whistleblowers will be protected.

In addition, everyone at the company acknowledges that we have a responsibility to look out for any risks and we take steps to minimise those risks.

Our Procedures to combat modern slavery:

1. We perform due diligence with all new schools before agreeing to supply our teachers to them. This includes looking at Ofsted reports.
2. Recruitment – we operate a robust recruitment policy and as part of the Recruitment and Employer Confederation (The REC) we follow their code of professional practice: https://www.rec.uk.com/recruiters/compliance/code-professional-practice 
3. Whistleblowing – As part of their training all prospective supply teachers, cover supervisors and teaching assistants are given access to a form they can fill in anonymously to raise any concerns or complaints they have. 
4. Work Environment Policy- As part of their training everyone who works with Humly can see our code of conduct which includes information on how we provide a healthy working environment.  
5. Everyone working at Humly LTD is made aware of the government guidelines on Modern slavery and the important things to look out for. Our training includes a number of links to government resources which employees are told to look at. These include a booklet called, “Modern Slavery Awareness & Victim Identification Guidance,” a set of videos called “GLAA Videos,” and another guide called, “Labour Exploitation Spot the signs.” We also share the governments ‘Modern Slavery is closer than you think,” campaign page.

Further steps 

We intend to take the following further steps to combat slavery and human trafficking: 

1. Risk assess all new suppliers using the Global Slavery Index and ask them to certify that they have taken steps to eradicate modern slavery within their organisation and supply chain.
2. Provide training to relevant Group employees to ensure a high-level understanding of the risks of modern slavery and human trafficking; and 
3. Where appropriate we will include a reference to the Modern Slavery Act 2015 in our policies and procedures. 
4. In order to evaluate the success of this policy, we will conduct an annual review where we speak to a randomly selected group of people employed with Humly to test their knowledge around modern slavery and assess if they know Humly’s procedures for reporting any issues related to modern slavery.

This statement was approved by the Board of Directors of Humly Ltd on 7th October 2017.

Signed by
Gustav Bild-Tofftin CEO, Humly Ltd.
October 2020