MODERN SLAVERY STATEMENT

Introduction from Nicholas Kirk , Chief Executive Officer, PageGroup plc

PageGroup’s purpose is to change lives. We are therefore fully committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.

Our Employee and Supplier Codes of Conduct make clear that we expect our own people and everyone employed by our suppliers, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

Nicholas Kirk
Chief Executive Officer
June 2025

PageGroup Structure
We are a global specialist recruitment consultancy. Our parent company is PageGroup plc and together with its subsidiaries, operates across 37 countries (together the “Group”).

The Group delivers permanent and temporary recruitment services and solutions, has c.7,400 employees worldwide and a global annual revenue of c.£1.7bn. Our business is organised as follows: Core recruitment services are managed regionally across Europe, Middle East and Africa, the UK, Asia Pacific and the Americas. Our Core business offers permanent and temporary recruitment services across a wide range of disciplines.

Page Executive, our specialist executive search business operates globally, as does our Enterprise Solutions business, which identifies global recruitment solutions for large Enterprise clients and includes our recruitment outsourcing services. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

In the UK, and across the world, we aim to work with a small range of suppliers who provide services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain.

Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. An annual assessment is undertaken by our Group procurement team and we do not consider that we operate in a particularly high-risk sector. Our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery). When appraising our supply chain, a risk-based approach has been developed, focussing on:

a) products we buy that are imported from countries identified as having a high risk of modern slavery; and
b) services we consume across industries where modern slavery is typically more prevalent.

In terms of the products we buy, the Group has referred to the Global Slavery Index’s list of products with identified risk of forced labour by source countries ¹. The only product areas identified as presenting a higher risk of modern slavery to PageGroup were:-

Electronics - Laptops, peripheral devices and mobile phones.
Timber / Textiles – used within office fit-out projects.
Coffee - consumed within our offices

In terms of the services we consume, the Group has consulted the UK Government’s guidance note on tackling modern slavery in supply chains ² in addition to the Gangmasters & Labour Abuse Authority (GLAA) industry profiles ³ setting out those sectors identified as representing most risk. Our risk assessments have determined that cleaning and couriers represent service lines that carry a higher risk of modern slavery.PageGroup, like with many other corporate organisations typically consumes products and services in these areas from globally recognised firms who we require to have established modern slavery policies and practices in place, and we continue to monitor their activities on an annual basis. The Group has continued to enhance our due diligence checks on UK suppliers falling within these risk areas over the past 12 months to ensure they can all exhibit one or more of the following criteria to underline their commitment to and controls over modern slavery: -

Hold a globally recognised sustainability rating by Ecovadis of at least Bronze or above (these assessments rate businesses based on labour and human rights standard, ethics, procurement practices and environmental impacts).
Achieved accreditation such as ISO9001, ISO14001 or ISO45001 which require organisations amongst other criteria to implement effective processes for the control of external suppliers of raw materials/ outsourced services.
Provide products which are PEFC ⁴ or FSC ⁵ certified.
Disclose the standards and obligations placed on their own business and supply chain partners within a Modern Slavery Statement or Supplier Code of Conduct.

We have also achieved an Ecovadis ‘Bronze’ assessment rating (in the top 35% of company scores) in recognition of the continued strong controls and commitment we have in place to safeguard against Labour & Human Rights risks in our supply chain. This evaluation process across both categories continues an annual basis.

Policy on Modern Slavery and Human Trafficking
Our employees are required to comply with our Employee Code of Conduct and our suppliers with our Supplier Code of Conduct.

These policies reflect our commitment to acting ethically and with integrity in our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our business and UK supply chain.

We have additional measures in place to ensure that slavery does not occur in the supply chains of our non-UK businesses (see below).

Due Dilience Processes for Slavery and Human Trafficking
Our Own Business
PageGroup prohibits and condemns the use of all forms of forced labour including child labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” helpline operating across our worldwide business which employees and third party workers are encouraged to use to report any concerns.

As part of our own business we supply temporary personnel to a number of clients. We take our obligations seriously in this respect and have well established and audited procedures to ensure that those temporary workers are protected from the risks of modern slavery. Taking the UK as an example, we ensure that:

temporary workers have a right to work for the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
we take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
temporary workers receive compliant pay as determined by the Agency Workers Regulations 2011.

In addition, all our employees, through the Employee Code of Conduct, are made aware of PageGroup’s requirement for employees to support and uphold human rights principles and know that PageGroup will not tolerate, engage in or support the use of, forced labour.

Our Supply Chain
We recognise the role our employees can play in helping to identify modern slavery risks in the supply chain, and we continue to ensure our Group Procurement and Property & Facilities teams globally undertake annual refresher training and certification via the Chartered Institute of Procurement and Supply (CIPS). This ensures our team are aware of key human rights legislation and how to identify Modern slavery within the supply chain and what to do if it is suspected.

We have now embedded enhancements to our global vendor onboarding process so that all prospective vendors across the Group are asked to provide further assurance on their approach to human rights by either providing access to their Ecovadis assessment scorecard or by answering a series of supplementary questions focussed on Modern Slavery and other key sustainability criteria. Where relevant, the Group Procurement function aim to ensure supplier contracts include an obligation on suppliers to comply with the Modern Slavery Act 2015 and where appropriate also include rights of audit to help us identify unethical practices. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to either remedy such non-compliance or terminate our relationship.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistleblowers.

We reported to PageGroup Plc’s Board on modern slavery KPIs. The KPIs revealed no cause for further investigation. Our target remains to continue to have no instances of modern slavery.

In addition, outside the UK, we have continued our engagement programme by leveraging our modern slavery playbook which sets out practical guidance on how to approach modern slavery and how to engage with suppliers in respect of minimising our risks in this regard. We have also continued our annual certification process for non-UK PageGroup businesses regarding whether they have had, or are aware of, any instances of modern slavery and confirm that they have assessed their modern slavery risk and escalated any concerns to Group Procurement. There were no instances of modern slavery reported in Financial Year 2024 or to date in 2025.

Further Steps
Following a review of the effectiveness of the steps taken in the previous financial year to prevent modern slavery or human trafficking occurring in our business, we intend to take the following further steps during the course of the 2025 financial year:

Review our client onboarding process to determine whether further enhancements can be made to identify Modern Slavery risks.
Continue the annual modern slavery training and certification programme across the Group’s Procurement and Property teams based in our UK, Europe, Americas and APAC businesses.
Ensure our business outside of the UK continue to monitor, manage and report modern slavery risks in accordance with the modern slavery playbook.
Require annual certification of the non-UK PageGroup businesses regarding whether they have had, or are aware of, any instances of modern slavery and confirm that they have assessed their modern slavery risk and escalated any concerns to Group Procurement.
Continue to measure the performance of Tier 1 suppliers against KPIs.
Ongoing review of the insights gained from our vendor onboarding process to support the identification of potential improvement opportunities with high-risk suppliers.
Explore further possible improvement areas in conjunction with Ecovadis from our annual assessment to drive continuous improvement across the Groups internal control framework,
Work with our People and Culture team to identify opportunities to leverage our new global learning platform to deliver modern slavery training to our staff.
Continue to educate our suppliers on the benefits of undertaking an EcoVadis assessment and in doing so evidence an ongoing commitment to safeguarding against Labour & Human Rights risks in their supply chain.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the financial year ending 31 December 2024. The statement was approved by the PageGroup plc Board on 3rd June 2025.

Nicholas Kirk
Chief Executive Officer
June 2025

¹ Global Slavery Index - https://www.globalslaveryindex.org/
² Tackling Modern Slavery inGovernment Supply Chains Guidance - https://www.gov.uk/government/publications/ppn-0223-tackling-modern-slavery-in-government-supply-chains/ppn-0223-tackling-modern-slavery-in-government-supply-chains-html
³ GLAA Industry profiles - https://www.gla.gov.uk/who-we-are/modern-slavery/industry-profiles/
⁴ PEFC is the Programme for theEndorsement of Forest Certification - https://pefc.org/
⁵ FSC is the Forest StewardshipCouncil - https://uk.sc.org/

2024 Modern Slavery Statement

MODERN SLAVERY STATEMENT

Introduction from Nicholas Kirk , Chief Executive Officer, PageGroup plc

PageGroup’s purpose is to change lives. We are therefore fully committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

Nicholas Kirk
Chief Executive Officer
June 2024

The Group delivers permanent and temporary recruitment services and solutions, has c.7800 employees worldwide and a global annual revenue of c.£2bn. Our business is organised as follows: Core recruitment services are managed regionally across Europe, Middle East and Africa, the UK, Asia Pacific and the Americas. Our Core business offers permanent and temporary recruitment services across a wide range of disciplines.

Page Executive, our specialise executive search business operates globally, as does our Enterprise Solutions business, which identifies global recruitment solutions for large Enterprise clients and includes our recruitment outsourcing services. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. We do not consider that we operate in a particularly high-risk sector. Our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery). When appraising our supply chain, a risk-based approach has been developed, focussing on:

In terms of the products we buy, the Group has referred to the 2023 Global Slavery Index’s list of products with identified risk of forced labour by source countries¹. The only product areas identified as presenting a higher risk of modern slavery to PageGroup were:-

Electronics - Laptops, peripheral devices and mobile phones.
Timber / Textiles – used within office fit-out projects.

In terms of the services we consume, our risk assessments have determined that cleaning, couriers and confidential waste disposal services represent service lines that carry a higher risk of modern slavery.

PageGroup, like with many other corporate organisations typically consumes products and services in these areas from globally recognised firms who we require to have established modern slavery policies and practices in place, and we continue to monitor their activities on an annual basis. To provide additional assurance, we have undertaken enhanced due diligence on our UK suppliers over the past 12 months across these risk areas to ensure they can all exhibit one or more of the following criteria and in doing so underlining their commitment to and controls over modern slavery: -

Hold a globally recognised sustainability rating by Ecovadis of at least Bronze or above (these assessments rate businesses based on labour and human rights standard, ethics, procurement practices and environmental impacts)
Accreditation such as ISO9001, ISO14001 or ISO45001 which require organisations amongst other criteria to implement effective processes for the control of external suppliers of raw materials/ outsourced services.
Provide products which are PEFC² or FSC³ certified.
Disclose their own standards and obligations placed on supply chain partners within a Modern Slavery Statement or Supplier Code of Conduct

This evaluation process across both categories continues an annual basis.

Our Policy on Modern Slavery and Human Trafficking
Our employees are required to comply with our Employee Code of Conduct and our suppliers with our Supplier Code of Conduct.

We have additional measures in place to ensure that slavery does not occur in the supply chains of our non-UK businesses (see below).

Due Diligence Processes for Slavery and Human Trafficking

Our Own Business
PageGroup prohibits and condemns the use of all forms of forced labour including child labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” helpline operating across our worldwide business which employees and third party workers are encouraged to use to report any concerns.

temporary workers have a right to work for the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
we take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
temporary workers receive compliant pay as determined by the Agency Workers Regulations 2011.

Our Supply Chain
We recognise the role our employees can play in helping to identify modern slavery risks in the supply chain, and in response to this have trained and obtained certification via the Chartered Institute of Procurement and Supply (CIPS) for ethical procurement and supply for all of our UK based Procurement team. We also extended the scope of this training and certification to include all centralised Property and Facilities employees within the UK and Continental Europe, in addition to procurement employees in Europe and APAC.

Alongside incorporating due diligence queries in our UK RFP processes to identify our potential suppliers’ approach to modern slavery and risk profile, we have embedded enhancements to our global vendor onboarding process to request all prospective vendors to provide further assurance on their approach to human rights by either providing access to their Ecovadis assessment scorecard or by answering a series of supplementary questions focussed on Modern Slavery and other key sustainability criteria. Where relevant, the Group Procurement function aim to ensure supplier contracts include an obligation on suppliers to comply with the Modern Slavery Act 2015 and where appropriate also include rights of audit to help us identify unethical practices. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to either remedy such non-compliance or terminate our relationship.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistleblowers.

We reported to PageGroup Plc’s Board on modern slavery KPIs. The KPIs revealed no cause for further investigation.

Deliver Ethical Procurement training to Property & Procurement staff based in our North American and Latin American businesses.
Continue to measure the performance of Tier 1 suppliers against KPIs.
Continue with our monthly Environment, Social & Governance (ESG) working group to discuss the actions being taken in respect of modern slavery, share best practice and identify on-going improvements to our modern slavery risk framework.
Ensure our business outside of the UK continue to monitor, manage and report modern slavery risks in accordance with the modern slavery playbook.
Require annual certification of the non-UK PageGroup businesses regarding whether they have had, or are aware of, any instances of modern slavery and confirm that they have assessed their modern slavery risk and escalated any concerns to Group Procurement.
Further review the insights gained from Ecovadis and our enhanced onboarding checks to support the identification of further improvement opportunities with high-risk suppliers.
Investigate the viability of providing online modern slavery training to our Suppliers and employees to further raise awareness of modern slavery

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Group's slavery and human trafficking statement for the financial year ending 31 December 2023. The statement was approved by the PageGroup plc Board on 3rd June 2024.

Nicholas Kirk
Chief Executive Officer
PageGroup plc

June 2024

¹https://www.globalslaveryindex.org/
²PEFC is the Programme for the Endorsement of Forest Certification - https://pefc.org/
³FSC is the Forest Stewardship Council - https://uk.fsc.org/

2023 Modern Slavery Statement

MODERN SLAVERY STATEMENT

Introduction from Nicholas Kirk , Chief Executive Officer, PageGroup plc

PageGroup’s purpose is to change lives. We are therefore fully committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

Nicholas Kirk
Chief Executive Officer
June 2023

PageGroup Structure
We are a global specialist recruitment consultancy. Our parent company is PageGroup plc, the PageGroup group of companies trade under the core brands of PageGroup , PAGE EXECUTIVE, MICHAEL PAGE, PAGE PERSONNEL and PAGE OUTSOURCING (together the “Group”). The Group delivers permanent and temporary recruitment services and solutions, has c. 8,500 employees worldwide, operates in 37 countries and has a global annual revenue of c.2bn. The Group is organised into the following regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. We do not consider that we operate in a particularly high risk sector. Our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery). When appraising our supply chain, a risk based approach has been developed, focussing on:

products we buy that are imported from countries identified as having a high risk of modern slavery; and
services we consume across industries where modern slavery is typically more prevalent.

In terms of the products we buy, the Group has referred to the Global Slavery Index’s list of products with identified risk of forced labour by source countries¹. The only risk area identified relevant to PageGroup was in relation to Electronics - Laptops, computers and mobile phones. PageGroup, like with many other corporate organisations, consumes products in these areas from globally recognised firms who we require to have established modern slavery policies and practices in place, and we will continue to monitor their activities.

In terms of the services we consume, our risk assessments have determined that cleaning and recycling/waste disposal services represents the only service line which carries a higher risk of modern slavery.

This evaluation process across both categories continues on an annual basis.

Our Policy on Modern Slavery and Human Trafficking

Our employees are required to comply with our Employee Code of Conduct and our suppliers with our Supplier Code of Conduct.

We have additional measures in place to ensure that slavery does not occur in the supply chains of our non-UK businesses (see below).

Due Diligence Processes for Slavery and Human Trafficking

Our Own Business
PageGroup prohibits the use of all forms of forced labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” helpline operating across our worldwide business which employees and third party workers are encouraged to use to report any concerns.

temporary workers have a right to work for the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
we take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
temporary workers receive compliant pay as determined by the Agency Workers Regulations 2011.

Our Supply Chain
We recognise the role our employees can play in helping to identify modern slavery risks in the supply chain, and in response to this have trained and obtained certification via the Chartered Institute of Procurement and Supply (CIPS) for ethical procurement and supply for all of our UK based Procurement team. We have extended the scope of this training and certification to include all centralised Property and Facilities employees within the UK and Continental Europe, in addition to procurement employees in Europe and APAC.

Alongside incorporating due diligence queries in our UK RFP processes to identify our potential suppliers’ approach to modern slavery and risk profile, we have proposed enhancements to our vendor onboarding process in the UK to request all prospective vendors to provide further assurance on their approach to human rights. Supplier contracts place an obligation on suppliers to comply with the Modern Slavery Act 2015 and where appropriate also include rights of audit to help us identify unethical practices. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to either remedy such non-compliance or terminate our relationship.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistleblowers.

We reported to PageGroup Plc’s Board on modern slavery KPIs. The KPIs revealed no cause for further investigation.

Continue to measure the performance of Tier 1 suppliers against KPIs.
Continue with our modern slavery working group comprised of senior leaders from our Legal, Procurement, Property and Sustainability functions. This group will continue to meet to discuss the actions being taken in respect of modern slavery, share best practice and identify on-going improvements to our modern slavery risk framework.
Ensure our business outside of the UK continue to monitor, manage and report modern slavery risks in accordance with the modern slavery playbook.
Require annual certification of the non-UK PageGroup businesses regarding whether they have had, or are aware of, any instances of modern slavery and confirm that they have assessed their modern slavery risk and escalated any concerns to Group Procurement.
Implement further enhancements to our UK vendor onboarding and assurance processes by:
- embedding independent business sustainability ratings into our due diligence processes across 4 themes: human rights & labour, ethics, environment, and sustainable procurement; and
- leveraging the insights gained from enhanced vendor due diligence and assurance checks to support the identification of continuous improvement opportunities with key suppliers.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 is reviewed and adopted by the Board and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2022.

Nicholas Kirk
Chief Executive Officer
PageGroup plc

June 2023

¹https://www.globalslaveryindex.org/

2022 Modern Slavery Statement

MODERN SLAVERY

Introduction from Steve Ingham, Chief Executive Officer, PageGroup plc

PageGroup’s purpose is to change lives for people through creating opportunity to reach potential. We are therefore fully committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.

Our Employee and Supplier Code of Conduct Codes of Conduct make clear that we expect our own people and everyone employed by our suppliers, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

Steve Ingham
Chief Executive Officer
31 May 2022

PageGroup Structure
We are a global specialist recruitment consultancy. Our parent company is PageGroup plc, the PageGroup group of companies trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE, PAGE PERSONNEL and PAGE OUTSOURCING (together the “Group”). The Group delivers permanent and temporary recruitment services and solutions, has c. 7,500 employees worldwide, operates in 37 countries and has a global annual revenue of c.£1.6bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services, we consider our supply chain to be relatively simple in comparison to many other industries.

Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high-risk sector. That said, when appraising our supply chain, a risk based approach has been developed, focussing on:

products we buy that are imported from countries identified as having a high risk of modern slavery; and
services we consume across industries where modern slavery is typically more prevalent.

This evaluation process across both categories continues on an annual basis.

Our Policy on Modern Slavery and Human Trafficking

Our employees are required to comply with our Employee Code of Conduct and our suppliers with our Supplier Code of Conduct.

We have additional measures in place to ensure that slavery does not occur in the supply chains of our non-UK businesses (see below).

Due Diligence Processes for Slavery and Human Trafficking

Our Own Business

PageGroup prohibits the use of all forms of forced labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” helpline operating across our worldwide business which employees and third party workers are encouraged to use to report any concerns.

As part of our own business, we supply temporary personnel to a number of clients. We take our obligations seriously in this respect and have well established and audited procedures to ensure that those temporary workers are protected from the risks of modern slavery. Taking the UK as an example, we ensure that:

temporary workers have a right to work for the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
we take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
temporary workers receive compliant pay as determined by the Agency Workers Regulations 2011.

Our Supply Chain

We include due diligence queries in UK RFP processes to identify our potential suppliers’ approach to modern slavery and these assist in our determination of whether the supplier should be considered a high risk supplier. A high risk supplier is sent a questionnaire so we can further assess their approach to the issue of modern slavery.
Supplier contracts place an obligation on suppliers to comply with the Modern Slavery Act 2015 and where appropriate also include rights of audit to help us identify unethical practices. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would terminate our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistle blowers.

In the last 12 months we engaged with our UK high-risk suppliers to ensure awareness of our “Speak-Up” helpline for their employees. A modern slavery questionnaire was issued to pose questions across a number of key areas, including (but not limited to):

Human trafficking
Auditing
Whistleblowing
Breach monitoring

We reported to PageGroup plc’s Board on modern slavery KPIs. The KPIs revealed no cause for further investigation.

In addition, outside the UK, a modern slavery playbook was devised and communicated to all the regions in which we operate providing practical guidance on how to approach modern slavery risk.

we will continue to operate the following KPIs: number of upheld complaints (we have a zero-tolerance approach) and in respect of high risk suppliers providing services to our UK business, % of these Tier 1 suppliers mapped and risk assessed and % of engagement and/or audits carried out regarding modern slavery compliance;
ensure the Group procurement team have successfully undertaken and passed the Chartered Institute of Procurement and Supply (CIPS) ethical training module;
further enhance our vendor onboarding processes to ensure all new vendors supplying goods/services to the UK are asked to provide detailed information on their human rights policies, practices and approach to managing risk;
continue with our modern slavery working group comprised of senior leaders from our Legal, Procurement and Facilities functions, which was established in 2020. The group will continue to meet to discuss the actions being taken in respect of modern slavery; and
ensure our businesses outside of the UK continue to monitor, manage and report modern slavery risks.

Steve Ingham,
Chief Executive Officer
PageGroup plc

Date: 31 May 2022

¹https://www.globalslaveryindex.org/

2021 Modern Slavery Statement

Modern Slavery

Introduction from Steve Ingham, Chief Executive Office, PageGroup plc

Our Employee and Supplier Code of Conduct make clear that we expect our own people and everyone employed by our suppliers, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

Steve Ingham
Chief Executive Officer
3 June 2021

PageGroup Structure
We are a global specialist recruitment consultancy. Our parent company is PageGroup plc, the PageGroup group of companies trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE, PAGE PERSONNEL and PAGE OUTSOURCING (together the “Group”). The Group delivers permanent and temporary recruitment services and solutions, has c. 7,000 employees worldwide, operates in 37 countries and has a global annual revenue of c.£1.3bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high risk sector That said, when appraising our supply chain, a risk based approach has been developed, focussing on:

Products we buy that are imported from countries identified as having a high risk of Modern Slavery; and
Services we consume across industries where Modern Slavery is typically more prevalent.

In terms of the products we buy, the Group has referred to the Global Slavery Index’s list of products with identified risk of forced labour by source countries¹. The only risk area identified relevant to PageGroup was in relation to Electronics - Laptops, computers and mobile phones. PageGroup, like with many other corporate organisations, consumes products in these areas from globally recognised firms who we require to have established Modern Slavery policies and practices in place, and we will continue to monitor their activities.

In terms of the services we consume, our risk assessments have determined that Cleaning and recycling/waste disposal services represents the only service line which carries a higher risk of Modern Slavery.

This evaluation process across both categories continues on an annual basis.

¹https://www.globalslaveryindex.org/

Our Policy on Modern Slavery and Human Trafficking
Our Employees are required to comply with our Employee Code of Conduct and our Suppliers with our Supplier Code of Conduct.

Due Diligence Processes for Slavery and Human Trafficking
Our Own Business

have a right to work the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
receive compliant pay as determined by the Agency Workers Regulations 2011.

Our Supply Chain

Supplier contracts contain anti-modern slavery clauses which place an obligation on suppliers to comply with the Modern Slavery Act 2015 and rights of audit to help us identify unethical practices. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would terminate our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistle blowers.

In the last 12 months we engaged with our UK high-risk suppliers to ensure awareness of our “Speak-Up” helpline for their employees. Furthermore, a Modern Slavery questionnaire was created and issued to gain further assurance on their compliance and maturity. The questionnaire posed questions across a number of key areas, including (but not limited to):

Human trafficking
Auditing
Whistleblowing
Breach monitoring

Responses have been reviewed and we are satisfied with the assurances provided by our suppliers although we will, as a matter of best practice, continue to keep monitoring their modern slavery compliance. We also reported to the Company’s Board on modern slavery KPIs introduced in 2020. The KPIs revealed no cause for further investigation.

we will continue to operate the following KPIs: number of upheld complaints (we have a zero tolerance approach) and in respect of high risk suppliers providing services to our UK business, % of tier 1 suppliers mapped and risk assessed and % of engagement and/or audits carried out regarding modern slavery compliance; and
in addition to the ongoing monitoring, we intend to on-board UK medium risk suppliers to the modern slavery assurance programme.

Outside of the UK, a Modern Slavery playbook will be devised and communicated to all the regions in which we operate providing practical guidance on how to approach Modern Slavery and support in managing these risks in our local businesses. In accordance with the risk-based approach developed in the UK, the focus for regions and their respective supply chains will continue to be on:

Products we buy that are imported from countries identified as having a high risk of Modern Slavery; and
Services we consume within countries across industries where Modern Slavery is typically more prevalent.

Steve Ingham, Chief Executive Officer
PageGroup plc

Date: 3 June 2021

2020 Modern Slavery Statement

Modern Slavery

Introduction from Steve Ingham, Chief Executive Office, PageGroup plc

Our Employee Code of Conduct and Supplier Code of Conduct make clear that we expect our own people and everyone employed by our suppliers, whether permanent or temporary, to be treated with respect and dignity at work and we believe employment should always be chosen. There must be no forced, bonded or involuntary labour. Employees must not be required to lodge monies or identity papers to be able to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the actions we have taken to mitigate modern slavery within our supply chain and the steps we intend to take over the coming year.

Steve Ingham
Chief Executive Officer
4 June 2020

PageGroup Structure
We are a global specialist recruitment consultancy. Our parent company is PageGroup plc, the PageGroup group of companies trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE, PAGE PERSONNEL and PAGE OUTSOURCING (together the “Group”). The Group delivers permanent and temporary recruitment services and solutions, has c. 7,000 employees worldwide, operates in 36 countries and has a global annual revenue of c.£1.5bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

In the UK we work with a small range of suppliers who provide services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain.

Risk and Compliance
PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its UK supply chain through its Internal Audit Function in combination with the Group Procurement Team. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high risk sector. This evaluation process continues on an annual basis.

Our Policy on Modern Slavery and Human Trafficking
Our Employees are required to comply with our Employee Code of Conduct and our Suppliers with our Supplier Code of Conduct.

Due Diligence Processes for Slavery and Human Trafficking
Our Own Business

PageGroup prohibits the use of all forms of forced labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a confidential third party operated “Speak-Up” helpline which employees are encouraged to use to report any concerns.

have a right to work the duration of their assignment. This involves asking the individual directly to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel while they are on assignment on our client’s premises, they are always free to leave their assignment; and
receive compliant pay as determined by the Agency Workers Regulations 2011.

In addition, our employees, through the Employee Code of Conduct, are made aware of PageGroup’s requirement for employees to support and uphold human rights principles and know that PageGroup will not tolerate, engage in or support the use of, forced labour.

Our Supply Chain

We map and risk assess our tier 1 suppliers who provide goods and services directly to our UK business. We include due diligence queries in UK RFP processes to identify our potential suppliers’ approach to modern slavery and these assist in our determination of whether the supplier should be considered a high risk supplier. A high risk supplier is sent a questionnaire so we can further assess their approach to the issue of modern slavery.

UK supplier contracts contain anti-modern slavery clauses which place an obligation on suppliers to comply with the Modern Slavery Act 2015 and rights of audit to help us identify unethical practices. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance or we would terminate our relationship with the supplier.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistle blowers.

In the last 12 months we established a Working Group comprised of senior leaders from our Legal, Procurement and Facilities functions who meet to discuss the actions being taken in respect of the Group’s anti-modern slavery strategy. We also provided guidance, training and support on modern slavery matters to our facilities and procurement teams by running externally facilitated training to help identify any modern slavery issues.

Further Steps
Following a review of the effectiveness of the steps taken in the previous financial year to prevent modern slavery or human trafficking occurring in our business and UK supply chain, we intend to take the following further steps during the course of the 2020 financial year:

we will engage with our UK high risk suppliers to ensure awareness of our “Speak-Up” helpline for their employees; and
implement a defined set of KPIs relating to: number of upheld complaints (we have a zero tolerance approach) and in respect of high risk suppliers providing services to our UK business, % of tier 1 suppliers mapped and risk assessed and % of engagement and/or audits carried out regarding modern slavery compliance.

Steve Ingham, Chief Executive Officer
PageGroup plc

Date: 4 June 2020

2019 Modern Slavery Statement

Modern Slavery

Introduction from Steve Ingham, Chief Executive Office, PageGroup plc

At PageGroup we believe in the importance of equality in the workplace. Being a responsible corporate citizen is not only the right thing to do, it is good for the long term viability of our business. We have an established Employee Code of Conduct which details the standards by which we operate. We expect these same high standards from our suppliers. We are committed to preventing acts of modern slavery and human trafficking from occurring within our business and the supply chain.

Our PageGroup Supplier Code of Conduct makes it clear that we expect the staff employed by our suppliers, whether permanent or temporary, to have the same basic right to be treated with respect and dignity at work as our own employees. We believe employment should be chosen. There must be no forced, bonded or involuntary labour. Supplier employees must not be required to lodge monies or identity papers in order to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the work we have completed to date to combat modern slavery within our business and the steps we intend to take over the coming year.

Steve Ingham
Chief Executive Officer
10 June 2019

Modern slavery is a global issue which can affect any business in any sector and which is often very difficult to detect. PageGroup recognises and takes very seriously the risk of modern slavery to our business and our people and we are committed to taking steps to reduce the risk of this abhorrent crime occurring within our business and supply chain.

PageGroup Structure
We are a global specialist recruitment consultancy. Our parent company is PageGroup plc, the PageGroup group of companies trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE, PAGE PERSONNEL and PAGE OUTSOURCING (together the “Group”). The Group delivers permanent and temporary recruitment services and solutions, has over 7,000 employees worldwide, operates in 36 countries and has a global annual revenue of over £1.5bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our Supply Chain
As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

In the UK we work with a small range of suppliers who provide goods and services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain.

On an on-going basis we risk assess our supply chain and at this time we consider that there is a relatively low risk of labour exploitation or other forms of slavery and human trafficking occurring within it. Nevertheless, we are committed to preventing these practices from occurring within both our business and our supply chain, which is demonstrated by our policies and due diligence procedures as outlined below.

Our Policy on Modern Slavery and Human Trafficking
Our Employees are required to comply with our Employee Code of Conduct and our Suppliers with our Supplier Code of Conduct.

Due Diligence Processes for Slavery and Human Trafficking
Our Own Business

PageGroup prohibits the use of all forms of forced labour and any form of human trafficking as set out in the Employee Code of Conduct. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with employment laws and a whistleblowing helpline which employees are encouraged to use to report any concerns.

In the UK, we ensure that temporary workers:

have a right to work in the UK for the duration of their assignment. This involves asking the individual direct to view their relevant identity documentation. A delay in providing proof of identity and/or associated right to work documentation might indicate a modern slavery issue and would be escalated appropriately;
take relevant references to ensure the individual is hired in a role that they have both the qualifications and experience to undertake;
we carry out detailed background checks and ensure all contracts comply with all legal requirements regarding workers’ rights;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid;
where we are responsible for such temporary personnel whilst they are on assignment on our client’s premises, they are always free to leave their assignment; and
receive compliant pay as determined by the Agency Workers Regulations 2011.

Our Supply Chain

As part of our initiative to identify, monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, we have undertaken the following due diligence procedures:-

(a) we have mapped our tier 1 suppliers who provide goods and services direct to our UK business;

(b) we have assessed each of those suppliers in the UK supply chain and ranked each as either a high, medium or low risk (relative to what we perceive to be the risk generally to our UK supply chain);

(c) we have ensured that all UK RFP processes include a series of due diligence queries designed to identify potential suppliers’ approach to modern slavery and enable determination of whether they should be considered high risk;

(d) in addition, each UK supplier that we rank as a high risk has either been sent a questionnaire so we can further assess their approach to the issue of modern slavery or their approach to modern slavery has been assessed;

(e) our terms and conditions with our key UK suppliers include anti-modern slavery clauses which place an obligation on suppliers to comply with the Modern Slavery Act 2015 and contain rights of audit to help us identify unethical practices; and

(f) we have provided guidance and support to our procurement teams on modern slavery matters.

If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would consider terminating our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistle blowers.

Key Performance Indicators
Given our view that PageGroup's exposure to modern slavery risk is limited, and the existing due diligence processes we already have in place as an organisation, we have not implemented key performance indicators in relation to modern slavery and human trafficking during the previous financial year.

Further Steps
Following a review of the effectiveness of the steps taken in the previous financial year to prevent modern slavery or human trafficking occurring in our business and UK supply chain, we intend to take the following further steps in relation to slavery and human trafficking during the course of the 2019 financial year:

continue to monitor the risk to our UK supply chain on an ongoing basis;
provide deep-dive, refresher training for our global procurement team; and
establish a modern slavery working group to consider actions that can be taken to minimise the risk of modern slavery across the supply chain and/or whether any key performance indicators could be introduced.

Steve Ingham, Chief Executive Officer
PageGroup plc

Date: 10 June 2019

2018 Modern Slavery Statement

Modern Slavery

We are publishing this statement to explain the work we have completed to date to combat modern slavery within our business and the steps we intend to take over the coming year.

Steve Ingham

Chief Executive Officer

7 June 2018

Modern slavery is a global issue which can affect any business in any sector and which is often very difficult to detect. It is extremely difficult if not impossible for any international organisation to guarantee that its business and supply chain is slavery free but PageGroup recognises and takes very seriously the risk of modern slavery to our business and our people and we are committed to taking steps to reduce the risk of this abhorrent crime occurring within our business and supply chain.

PageGroup Structure

We are a global specialist recruitment consultancy, the parent company of the PageGroup plc group of companies who trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE and PAGE PERSONNEL (Group). The Group has over 7,000 employees worldwide, operating in 36 countries, with a global annual revenue of over £1.3bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our UK Supply Chain

As a provider of recruitment services we consider our supply chain to be relatively simple in comparison to many other industries.

Having performed a risk assessment of our UK supply chain we consider that there is a relatively low risk of labour exploitation or other forms of slavery and human trafficking occurring within it. Nevertheless, we are committed to preventing these practices from occurring within both our business and our supply chain, which is demonstrated by our policies and due diligence procedures as outlined below.

Our Policy on Modern Slavery and Human Trafficking

Our UK suppliers are required to comply with our Employee Code of Conduct (which also applies to all PageGroup employees globally) and with our PageGroup Supplier Code of Conduct

Due Diligence Processes for Slavery and Human Trafficking

Our Own Business

PageGroup prohibits the use of all forms of forced labour and any form of human trafficking. We have a number of procedures in place in relation to our employees to proactively manage any risk, including robust recruitment processes in line with UK employment laws and a whistleblowing helpline which employees are encouraged to use to report any concerns.

As part of our own business we supply temporary personnel to a number of clients. In this respect we have established and audited procedures to ensure that those employees:-

have a right to work in the UK. This involves asking the individual direct to view their passport. A delay in providing the passport might indicate a modern slavery issue;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid; and
where we are responsible for such temporary personnel whilst they are employed on our client’s premises, they are free to leave their assignment on reasonable notice.

Our Supply Chain

As part of our initiative to identify, monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, we have undertaken the following due diligence procedures:-

(a) we have completed the mapping of our tier 1 suppliers who provide goods and services direct to our UK business;

(b) we have assessed each of those suppliers in the UK supply chain and ranked each as either a high, medium or low risk (relative to what we perceive to be the risk generally to our UK supply chain);

(c) we wrote to all our UK supplier to note our commitment to transparency and combatting modern slavery within our own organisation and our similar expectation from suppliers of goods and services to us, sending each supplier the PageGroup Supplier Code of Conduct and requesting a signed confirmation from those suppliers that they adhere to our required standards;

(d) in addition, each UK supplier that we ranked as a high risk has been sent a questionnaire so we can further assess their approach to the issue of modern slavery;

(e) we have reserved the right with our all UK suppliers to request access to their facilities for members of our Internal Audit Team to check compliance with the PageGroup Supplier Code of Conduct. Such on-site audits would also help us to identify whether a supplier was engaged in unethical practices, which might include forced labour or other forms of modern slavery;

(f) we have updated our terms and conditions with our key UK suppliers to include anti-modern slavery clauses which place an obligation on suppliers to comply with the Modern Slavery Act 2015; and

(g) key members of the Group Procurement Team have received initial training on the issue of modern slavery.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistle blowers.

Risk and Compliance

PageGroup has evaluated the nature and extent of its exposure to the risk of modern slavery occurring in its UK supply chain through its Internal Audit Function in combination with the Group Procurement Team. As our core business is focused on the provision of recruitment services in respect of professionals, office and administrative workers (rather than in relation to agriculture, retail or manufacturing, which are sectors we perceive to present a higher risk of labour exploitation and modern slavery), we do not consider that we operate in a particularly high risk sector. This evaluation process will continue on an annual basis.

Training and Performance Indicators

Given our view that PageGroup's exposure to modern slavery risk is limited, and the existing due diligence processes we already have in place as an organisation, except as noted above, we have not implemented any specific training of our UK employees or key performance indicators in relation to modern slavery and human trafficking during the previous financial year.

Further Steps

Following a review of the effectiveness of the steps taken in the previous financial year to prevent modern slavery or human trafficking occurring in our business and UK supply chain, we intend to take the following further steps to combat slavery and human trafficking during the course of the 2018 financial year:

continue to monitor the risk to our UK supply chain on an ongoing basis;
implement specific training of all UK based employees to ensure a high level of understanding of the risks of modern slavery and so they are aware of what to look out for in respect of modern slavery; and
consider further how best to map the supply chains of our overseas businesses.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2017.

Steve Ingham, Chief Executive Officer

PageGroup plc

Date: 7 June 2018

2017 Modern Slavery Statement

We have developed a PageGroup Supplier Code of Conduct which makes it clear that we expect the staff employed by our suppliers, whether permanent or temporary, to have the same basic right to be treated with respect and dignity at work as our own employees. We believe employment should be chosen. There must be no forced, bonded or involuntary prison labour. Supplier employees must not be required to lodge monies or identity papers in order to work and must be free to leave employment after the giving of reasonable notice.

We are publishing this statement to explain the work we have completed to date to combat modern slavery within our business and the steps we intend to take over the coming year.

PageGroup Structure

We are a global specialist recruitment consultancy, the parent company of the PageGroup plc group of companies who trade under the core brands of PAGEGROUP, PAGE EXECUTIVE, MICHAEL PAGE and PAGE PERSONNEL (Group). The Group has over 6,000 employees worldwide, operating in 36 countries, with a global annual revenue of over £1.1bn. The Group is organised into four regions: Europe, Middle East and Africa; the UK; Asia Pacific; and the Americas. To find out more about the nature of our business please click here.

Our UK Supply Chain

As a provider of recruitment services we do not have a particularly long or complex supply chain. In the UK we work with a small range of suppliers who provide goods and services across a number of different categories, such as property and facilities management, IT and telecoms, marketing, legal and other services. Therefore, we have close relationships with our suppliers and good visibility of our supply chain, and do not feel that it is particularly susceptible to labour exploitation or other forms of slavery and human trafficking. Nevertheless, we are committed to preventing these practices from occurring within both our business and our supply chain, which is demonstrated by our policies and due diligence procedures as outlined below.

Our Policy on Modern Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in our business. Our UK suppliers are required to comply with our PageGroup Supplier Code of Conduct and Employee Code of Conduct which reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our UK supply chain.

Due Diligence Processes for Slavery and Human Trafficking

Our Own Business

As part of our own business we supply temporary personnel to a number of clients. In this respect we have established and audited procedures to ensure that those employees:-

have a right to work in the UK. This involves asking the individual direct to view their passport. A delay in providing the passport might indicate a modern slavery issue;
where we provide payroll services as required by our own clients, we check that such temporary personnel have a bank account in their own name into which their remuneration is paid; and
where we are responsible for such temporary personnel whilst they are employed on our client’s premises, they are free to leave their assignment on reasonable notice.

Our Supply Chain

As part of our initiative to identify, monitor and reduce the risk of slavery and human trafficking occurring within our supply chain, we have undertaken the following due diligence procedures:-

(a) we have commenced the mapping of suppliers who provide goods and services to our UK business to identify those suppliers whose goods or services are heavily dependent on the provision of people;

(b) we have started to assess those suppliers in the UK supply chain who we believe are in a high risk area, and have written to each such supplier to note our commitment to transparency and combatting modern slavery within our own organisation and our similar expectation from suppliers of goods and services to us. We have sent to these suppliers the PageGroup Supplier Code of Conduct and requested a signed confirmation from those suppliers that they adhere to our required standards; and

(c) we have reserved the right with our suppliers to request access to their facilities for members of our Internal Audit Team to check compliance with the PageGroup Supplier Code of Conduct. Such on-site audits would also help us to identify whether a supplier was engaged in unethical practices, which might include forced labour or other forms of modern slavery.

We will also follow this process with those further suppliers identified as we complete our supplier mapping work, and with new suppliers. We will include appropriate terms in our agreements which place an obligation on suppliers to comply with the Modern Slavery Act 2015. If we were to find evidence that one of our suppliers has failed to comply with the Modern Slavery Act 2015 then we would require the relevant supplier to remedy such non-compliance and we would consider terminating our relationship should we see no improvement in the way their business is conducted.

This approach is designed to:

identify and assess potential risk areas in our UK supply chain;
mitigate the risk of slavery and human trafficking occurring in the supply chain;
monitor potential risk areas in the supply chain; and
provide adequate protection to whistle blowers.

Risk and Compliance

Training and Performance Indicators

Given our view that PageGroup's exposure to modern slavery risk is limited, and the existing due diligence processes we already have in place as an organisation, we have not implemented any specific training or key performance indicators in relation to modern slavery and human trafficking during the previous financial year.

Further Steps

Following a review of the effectiveness of the steps we have taken so far this financial year to prevent modern slavery or human trafficking occurring in our business and UK supply chain we intend to take the following further steps to combat slavery and human trafficking during the course of the 2017 financial year:

to complete the mapping of our UK suppliers;
include appropriate anti-modern slavery terms in our agreements with suppliers;
continuing to raise awareness with our key teams provided through training to ensure a high level of understanding of the risks of modern slavery and so they are aware of what to look out for in respect of modern slavery; and
identify how best to map the supply chains of our overseas businesses.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 31 December 2016.

Steve Ingham, Chief Executive Officer

PageGroup plc

Date: 8 June 2017