Updated: November 2023

Protential Group is the trading name of Bluestone Personnel Ltd. and is an autonomous independent Company who employ all their own staff to recruit personnel on behalf of their clients. In light of Irish, European & UK general law on employment and human rights, and, more specifically, the UK Modern Slavery Act 2015, we have reviewed our existing compliance and risk management processes to determine to what extent measures already exist, and what further measures may be required to prevent slavery and human trafficking taking place in any part of our business.

The Scope of this Policy

Protential Group has adopted a number of policies and practices across the business with the aim of preventing modern slavery and human trafficking.

This policy governs all our business dealings and the conduct of all staff members who we appoint to act on our behalf. We expect all who have, or seek to have, a business relationship with Protential Group and/or any member of our business, to familiarise themselves with our anti-slavery values and policy and to always act in a way which is consistent with our anti-slavery values and policy.

This document sets out the policy of Protential Group with the aim of the prevention of opportunities for modern slavery to occur within its businesses. This policy’s use of the term “modern slavery” has the meaning given in the Act.

Protential Group Anti-Slavery Value

As part of our culture of good governance for good business, at Protential Group we operate to a set of core values which reflect our relationships with our principal stakeholder groups customers, suppliers, teams, and staff members.

We adopt a behavioural value for all our business relationships, reflecting our attitude. 

to the exploitation of individuals in any form, and more particularly the offences under the Modern Slavery Act 2015. We are committed to opposing modern slavery in all its forms and preventing it by whatever means we can. We demand the same attitude of all who work for us and expect it of all with whom we have business dealings.

We are dedicated to combatting and mitigating the risk of modern slavery and exploitation in our business operation.

Our attitude to modern slavery is: zero tolerance. We at Protential Group continue to collaborate with our customers, suppliers, and external partners to drive a leading approach to this issue. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our businesses or those of our suppliers.

Risk Assessment in Protential Group

  1. We are committed to ensuring there is transparency in our business and in our approach to tackling modern slavery consistent with our disclosure obligations under Irish and UK employment law. We expect the same exacting standards from all our suppliers and other business partners, and we are evolving and continually updating our processes to include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same exact standards.
  2. Protential Group is an active member of the GLAA licensing group. The Gang-masters and Labour Abuse Authority is the foremost investigative agency for labour exploitation in the UK. Its role is to work in partnership with police and other law enforcement agencies to protect vulnerable and exploited workers.
  3. The Company encourages members of the public or people not employed by us to write, in confidence, to the Company Secretary or the Company’s Head of Human Resources at New Town Centre, Killegland Street, Ashbourne, Co. Meath to raise any concern, issue or suspicion of modern slavery in any part of our business.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy. We are committed to ensuring no one suffers any detrimental treatment because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavorable treatment connected with raising a concern. The Company will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

  1. Our zero-tolerance approach to modern slavery must be communicated to all suppliers and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
  2. All our stakeholders have an obligation to familiarise themselves with our procedures and policy to help in the identification and prevention of modern slavery and to conduct business in a manner such that the opportunity for and incidence of modern slavery is prevented.
  3. Adherence to this policy forms part of all stakeholder’s obligations under their contract of employment.

Action Plan on Tackling Risk

Whilst recognising our statutory obligation to set out the steps we have taken to ensure that modern slavery and human trafficking is not taking place in our business, we acknowledge that we do not control the conduct of individuals and organisations outside of our own Company. To underpin our compliance with practical steps, we intend to implement the following measure when appropriate:

  1. Conduct risk assessments to determine which parts of our business and which of our suppliers are most at risk from modern slavery so that efforts are made in those areas.
  2. Engage with our suppliers both to convey to them our Anti-Slavery Policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
  3. Where appropriate, as informed by our risk assessment, seek to introduce supplier pre-screening (for example as part of our tender process) and self-­ reporting for our suppliers on safeguarding control.
  4. Introduce contractual provisions for our suppliers to confirm their adherence to this policy and accept our right to audit their activities and, where practicable, relationships, both routinely and at times of reasonable suspicion.

Responsibility for the Policy

Ultimate responsibility for the prevention of modern slavery rests with the Company leadership. The Directors of the Company have overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations.

Team leaders at all levels are responsible for ensuring those reporting to them fully understand and comply with this policy and are given adequate and regular training on the issue of modern slavery.