Modern Slavery Policy

Nova International Group — Modern Slavery Act Statement

Nova International is an award-winning, leading international recruitment agency, drawing upon 20 years of international recruitment expertise across the UK and Europe, Africa, United States and the Middle East.

We are committed to inclusion and diversity within the recruitment industry, training consultants in the latest best practice and putting it at the heart of everything; as well as tackling poverty, so donating a percentage of each commission to a charitable enterprise of the client’s choice, in a bid to support developing communities to become more self-sufficient in their recruitment.

Nova International Group Ltd (‘the Company’, ‘we’, ‘us’ or ‘our’) is fully committed to preventing modern slavery and human trafficking, whether in its own operations, supply chains or corporate activities.

Responsibility

The Company has overall responsibility for ensuring this policy complies with legal and ethical obligations, and the compliance of all in our organisation. The primary and daily responsibility for administering this policy is facilitated by our HR team, who oversee and implement the policies, due diligence and training necessary, monitoring its use and effectiveness, answering queries, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Policies

We operate the following internal policies to ensure our business operations are conducted ethically and with full transparency in our efforts to detect, prevent and/or flag any instances of modern slavery:

• Recruitment and Selection
  This policy ensures that all the procedures related to hiring and selection are performed transparently and conducted in a fair and legitimate manner. It seeks to ensure that discriminatory behaviour is avoided at any stage of the recruitment process – a candidate should never be discriminated against due to gender, race, sexual orientation, age, religion, nationality, political opinion, disability, or other.
  As an Equal Opportunities employer, we are committed to providing this respectful and inclusive working environment for everyone. In compliance with employment legislation and the Equality Act 2010, all employees involved in recruitment, selection and redundancy situations must apply consistent and unbiased criteria free from discrimination throughout the process.
  We operate a thorough recruitment policy, including carrying out checks on eligibility to work in the UK for all employees, to protect against human trafficking or anyone being forced to work against their will.
• Employee Code of Conduct
  This policy outlines the guiding principles and expectations for appropriate behaviour with merit in the workplace and elsewhere whilst representing the Company. We are committed to upholding the highest standards of ethical behaviour and practices when operating both within the business and out in the community, including supply chain management.
• Whistleblowing
  This policy ensures that the whistleblowing procedure is made safe and discreet for employees to make disclosures, without fear of reprisal. All employees are provided with access to channels through which they may voice concerns — we are committed to protecting them when disclosing malpractice and will ensure that all disclosures made in good faith will be treated confidentially.

We encourage all of our employees and associates to raise any concerns related to the Company, whether pertaining to direct activities or supply chains — including any circumstances which may signify a clear risk of modern slavery or human trafficking.

All policies are reviewed on an annual basis or as necessary dependent on legislative updates or operational and company policy changes.

Due Diligence

The Company practises due diligence in taking on new Clients and runs a system of regular checks and reviews as part of our commitment to countering modern slavery and human trafficking. In undertaking due diligence on our supply chain to ensure compliance with legislative obligations, this forms part of our contractual relationship with suppliers.

Our policies aim to:

• Identify, action and/or monitor potential risks within the Company and supply chains
• Reduce and eradicate risk of occurrence
• Focus on slavery and human trafficking to a higher degree where general risks are recognised, when carrying out internal audits through the Company’s own auditor
• Provide practical advice, help, training and/or support to employees and suppliers, and protection where required

Risk Assessment

The Company evaluates the nature and level of its exposure to the risk of modern slavery occurring in its supply chain, through assessing the potential risks of each new supplier.

Procedures to identify and mitigate risk include (but are not limited to):

• Carrying out systematic compliance checks on our supply chain
• Auditing and regularly reviewing our practices
• Encouraging the reporting of concerns and protection of whistleblowers

Nova International’s supply chains include, although are not limited to, sourcing candidates for clients. We have a zero tolerance for slavery and human trafficking and look to everyone in our supply chain and contractors to comply with our values. In the event there is indication of non-compliance with our policies and procedures, we would require the supplier to rectify the issue. We will not knowingly support or deal with any business involved in modern slavery, human trafficking or child labour.

Effectiveness

To ensure effectiveness of actions and policies counteracting modern slavery and human trafficking in its business and supply chains, the Company will:

Request and evaluate information from suppliers regarding their modern slavery practices
Train employees on an ongoing basis regarding modern slavery issues to continue raising awareness

Training

The Company requires all employees to undertake and complete awareness training on how to assess the risk of modern slavery and human trafficking, identify the signs and the steps that need to be taken to flag up potential issues in the event any indications are found. They will be familiarised with the contents of Modern Slavery Act 2015, and advised as to what help is available, such as the internal channels available or externally through the Modern Slavery Helpline.

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015, relating to activities and actions for the financial year 31 January 2021.

This statement has been approved by the board of directors.

Signed for and on behalf of Nova International Group Ltd., by:

Sunita Bhogal

Director