Last Updated June 2025

Policy Statement
This Policy and statement are in response to section 54 (1) of the UK Modern Slavery Act 2015 and outlines Links Group’s commitment to identifying and preventing modern slavery and human trafficking in any part of its business including all group companies. There are now as many as 40 million people in modern slavery, globally. It is estimated there are at least 10,000 modern slaves in the UK. Links Group, comprising Links Recruitment, Links Training, and HR Nationwide (trading as Privilege HR) holds a zero-tolerance position on slavery and human trafficking and will not tolerate or condone any form of slavery or human trafficking within any part of its business or supply chain. We as a business are committed to developing and adopting a proactive approach to tackling slavery and human trafficking through our policies, procedures and recruitment processes and look to engage with only those who have the same approach.

Scope of Policy

• This policy applies to all employees regardless of length of service. The scope of the policy also covers agency workers or self-employed contractors, interns, volunteers and visitors, whilst they are operating on or around company premises and will be made available on request.
• Employees of our Group companies and its subsidiaries must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf.
• This policy does not form part of any employee’s contract of employment, and it may be amended at any time.
• This policy will be reviewed annually and updated as required.

Our Business and Supply Chain

The Links Group is formed of Links Recruitment, Links Training and HR Nationwide (Operating as Privilege HR Cardiff & Bristol) and as such has an important part to play in the correct and legal recruitment, training and retention of both the temporary and permanent employees of our clients. We offer a range of recruitment solutions including permanent, temporary as well as on-site managed services as well as tailored training and development solutions to meet various client’s needs.

Our recruitment activities and the candidates and labour force provided to our clients are all UK based, and we do not use any overseas recruitment agents to source candidates.

Due Diligence

Links Group realises that the potential risk of slavery and human trafficking is a modern-day existence and can occur both internally and externally, especially when dealing with temporary contracts, suppliers and third parties.

Our employees are required to comply with and maintain the company’s Code of Conduct and we expect that any suppliers will have in place their own relevant policies and procedures and look to ensure this prior to entering into any agreement.

We are committed to ensuring that there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting process, we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children and we expect that our suppliers will hold their own suppliers to the same high standards.

Our Supply Chain

As a provider of recruitment services and training solutions we consider our supply chain to be relatively simple in comparison with many other industries or service providers.

All approved suppliers are subject to due diligence checks and regular reviews. We foster long term relationships with our approved suppliers, and we do not make demands nor issue instructions to suppliers that might lead to them violating human rights.

If a supplier does not meet Links Group’s standards and requirements, we will consider whether it is appropriate to work with them and, if necessary, either help them remedy any issues or where more appropriate take steps to terminate contracts.

Our Policies and Procedures

Links Group has a zero-tolerance approach to slavery and human trafficking of any kind within our business or supply chain. Our internal policies and procedures reflect our commitment to acting ethically and with integrity in all our business relationships, as well as looking to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place.

With specific reference to Links Recruitment, we are conscious that part of this business is set up to supply temporary employees to several of our clients, which could potentially be a higher risk activity. We have several procedures in place to proactively manage any risk, including robust recruitment processes that both comply with all relevant employment laws as well as enabling our employees to audit and review applicants, identify any areas of concern such as the sharing of bank details, home address and emergency contact information (this process is automated). We ensure that temporary workers:

• Have the correct Right to Work documentation and that this is available when requested with no delays
• Carry out checks in respect to workers age and ensure all contracts comply with all legal requirements regarding workers’ rights
• Where payroll services are provided, we ensure that bank account details are in the correct name and suitably approved
• Receive compliant pay in line with all legal requirements
• Where we are responsible for temporary workers, while they are employed at client’s premises, that they are always free to leave their placement.

Governance Structure

We are committed to the highest principles of personal and professional conduct which includes a zero-tolerance approach to modern slavery. Links Group and the team of Directors are responsible for ensuring that there is a satisfactory process in place for managing strategy, risk management and assessment, ethical and corporate social responsibility issues including modern slavery.

Whistleblowing

Our whistleblowing policy applies to everyone working within Links Group, including employees, contractors and third parties acting on behalf of Links Group. The policy provides a mechanism for the reporting of concerns about suspected wrongdoing or concerns at work, including slavery and human trafficking violations, without fear of reprisals.

Recruitment and Employment Practice

A robust recruitment policy and set of practices exist, in line with UK legislation, including right to work document checks, contracts of employment and ensuring that personal information provided is genuine and we are committed to fair employment practices for all our own employees.

• Our recruitment procedures include mandatory documentation checks to ensure that all employees are over 18 and are eligible to work in the applicable roles.
• We conduct annual pay reviews and benchmarking activities and implement working hours and pay staff wages which are compliant with all relevant laws.

Cross Reference with Other Documents

We also have various policies and procedures in place to further our commitment to tackling modern day slavery, including:

• Whistleblowing Procedure
• Bullying & Harassment Policy
• Equality, Diversity & Inclusion Policy
• Ethical Policy & Code of Conduct
• Data Protection Policy
• Anti-Bribery & Corruption Policy

This policy & statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is reviewed annually and adopted by the Board and constitutes our Group’s Modern Slavery and Human Trafficking Statement.

Any queries regarding this policy should be directed to hello@linksgroup.co.uk

For and on behalf of the Links Group:

Daniel Puttick

Chief Operating Officer (CEO)

Links Group

Date: 2^nd July 2025
Review Due: June 2026