Modern Slavery Policy

Modern Slavery Statement for Leap29

Introduction

Leap29 is committed to upholding the highest standards of ethical behaviour and integrity in all its business operations. We recognise our responsibility to ensure that modern slavery and human trafficking do not take place within our supply chain or any part of our business. This statement outlines the steps we have taken and continue to take to identify, assess, and mitigate the risks of modern slavery within our operations and supply chain.

Definitions

Leap29 considers that modern slavery encompasses:

• Human trafficking
• Forced work, through mental or physical threat
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
• Being dehumanised, treated as a commodity or being bought or sold as property
• Being physically constrained or having restrictions placed on freedom of movement

Our Business

Leap29 is a global recruitment and expansion service provider, delivering specialised staffing solutions across multiple industries, including energy, engineering, legal, and technology. Our operations span several countries, and we engage with a broad range of clients and suppliers worldwide.

Our Supply Chain

Given the nature of our business, we understand that risks of modern slavery could potentially arise in areas such as recruitment processes and the treatment of temporary workers.

We have a zero-tolerance approach to modern slavery and human trafficking within our supply chain. In the UK and the rest of the world, the majority of our supply chain incorporates business partners and professional consultancy services, namely industrial engineering, financial or legal specialists, or organisations that partner with Leap29 in the mobilisation of personnel. We consider the risks of forced labour and human trafficking to be relatively low in our supply chain but take proportionate steps to mitigate that risk.

Identified Risks

We have identified the following risks within our supply chain:

• Labour Exploitation: Particularly in regions with weaker labour laws, there is a risk of exploitation of workers, including through debt bondage, unfair wages, and unsafe working conditions.
• Subcontracting Risks: The use of subcontractors by our suppliers could lead to diminished oversight, increasing the risk of forced labour and human trafficking.
• Inadequate Due Diligence: Failure to properly vet our suppliers, particularly in high-risk regions, could result in association with unethical practices.

Our Commitment

Leap29 acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Leap29 understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Leap29 does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labour.

Leap29 is committed to the following actions to combat modern slavery:

• Ethical Recruitment: We adhere to fair recruitment practices, ensuring all candidates are recruited voluntarily and compensated fairly. We reject any form of forced, bonded, or involuntary labour.
• Supplier Code of Conduct: We require all our suppliers to comply with our Supplier Code of Conduct, which includes strict provisions against modern slavery and human trafficking.
• Risk Assessment: We conduct regular risk assessments to identify areas within our supply chain that may be vulnerable to modern slavery, and we take appropriate action to mitigate these risks.

Reporting and Whistleblowing

Leap29 encourages all employees, candidates, and suppliers to report any concerns related to modern slavery. We have established a confidential whistleblowing policy that allows individuals to report issues without fear of retaliation. All reports are thoroughly investigated, and appropriate action is taken.

Leap29 has appointed a slavery compliance officer to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to Leap29’s obligations.

Continuous Improvement

We are committed to continuously improving our approach to tackling modern slavery. This includes regularly reviewing and updating our policies, procedures, and training programs to ensure they remain effective and aligned with best practices.

Conclusion

Leap29 stands firm in its commitment to eradicating modern slavery within our business and supply chain. We will continue to work diligently to ensure that our operations uphold the principles of fairness, respect, and human dignity.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and has been approved by the Board of Directors.