1. Purpose of This Policy

At GrowMore Recruitment, we believe that every person deserves to live and work in conditions where dignity, fairness, and respect are not aspirational ideals but everyday realities. As a company deeply rooted in the recruitment, outsourcing, EoR, and workforce solutions space, we understand that the trust people place in us carries real human weight. Their wellbeing is not only our responsibility, it is a privilege we take to heart.

Modern slavery and human trafficking remain deeply troubling global issues, often hidden in plain sight and capable of affecting any labour market or supply chain. We recognise that our position across multiple jurisdictions and industries places us at the front line of both risk and responsibility. This is why our commitment to ethical conduct extends far beyond compliance. It reflects who we are, what we stand for, and the values that guide our work every day.

The purpose of this policy is to bring clarity and accountability to that commitment. It sets out our principles, defines our expectations of everyone we work with, and details the processes we use to prevent, detect, and respond to any form of exploitation. It ensures that every individual connected to GrowMore, whether an employee, contractor, candidate, partner, or client is protected by clear safeguards and treated with lawful, transparent, and compassionate care.

Ultimately, this policy is an expression of our belief that freedom, equality, and human rights must never be compromised. It reinforces our dedication to creating safe and empowering working environments, upholding the highest standards of ethical practice, and standing firmly against any conduct that undermines the wellbeing of the people we serve.

2. Scope

This policy applies to all areas of GrowMore Recruitment’s internal operations and external engagements.

It covers every GrowMore employee, manager, director, intern, or contractor, regardless of where they are based or which GrowMore brand they work under. It also extends to all labour we source, manage, place, or support through our recruitment, temporary staffing, volume hiring programmes, and Employer of Record (EoR) services.

The policy applies equally to the broader network of third parties that support our work, including suppliers, subcontractors, professional partners, technology vendors, training providers, marketing agencies, and any organisation operating on our behalf. Clients who utilise our services are also expected to meet the standards outlined here. As stewards of the recruitment process, we have a responsibility to ensure that exploitation has no place within our ecosystem.

3. Definition of Modern Slavery

Modern slavery is an umbrella term for severe forms of exploitation where individuals are deprived of freedom and are unable to refuse or leave work because of coercion, threats, deception, or abuse of power. It encompasses forced labour, human trafficking, bonded labour, involuntary servitude, deceptive recruitment practices, and situations where identity documents are withheld to restrict a person’s autonomy.

In the recruitment and workforce management context, modern slavery can arise in subtle forms: recruitment fees imposed on candidates, misleading job descriptions, pressure to accept unfavourable terms, or the manipulation of vulnerable individuals. At its worst, it includes outright coercion or physical control. GrowMore upholds the definitions set by the International Labour Organization, the United Nations, and modern slavery legislation in relevant jurisdictions. We adopt a broad interpretation to ensure that no form of exploitation is tolerated, even if not explicitly captured in a single legal definition.

4. Our Commitment

GrowMore Recruitment takes a firm stance against all forms of modern slavery and human trafficking. Our commitment is rooted in the belief that people are the core of our business, and safeguarding their rights is both an ethical obligation and a vital part of responsible corporate practice.

We commit to ensuring that every individual engaged through GrowMore is working voluntarily, receiving fair payment, and operating under lawful, safe, and respectful conditions. We actively reject business practices that compromise worker welfare, including hidden deductions, misleading job promises, or the retention of personal documents. We also commit to open communication, supporting workers if they raise concerns, and acting swiftly when any misconduct is identified. Our leadership and operational teams work continuously to strengthen our processes to ensure this commitment is upheld at every level of the business.

5. Governance and Accountability

Modern slavery prevention is a shared responsibility, but GrowMore assigns defined accountability to ensure proper oversight.

The Leadership Team holds strategic responsibility for ensuring the organisation’s operations align with global ethical standards. Leaders provide direction, allocate resources, and ensure compliance structures remain strong and effective.

Operational accountability sits with departmental heads across Recruitment, People & Culture, StaffCheck, EoR, Payroll, Vendor Management, and Legal. These teams are responsible for embedding ethical safeguards into their daily processes, from screening candidates to auditing suppliers. Their role includes monitoring for warning signs, engaging external specialists when needed, and ensuring that staff are properly trained.

Every employee, regardless of role, is accountable for maintaining our standards. We expect all staff to act immediately if they observe irregularities, report concerns without hesitation, and uphold the values that support this policy.

6. Due Diligence Processes

6.1 Recruitment Safeguards

GrowMore applies rigorous checks throughout the recruitment lifecycle to prevent exploitation. Candidates are properly identified, their legal right to work is verified, and their employment terms are communicated openly and clearly. We ensure that job advertisements accurately reflect the nature of the work and that no misleading or exaggerated claims are made.

Our teams hold responsibility for ensuring candidates are never charged recruitment fees, coerced into accepting roles, or pressured into unfavourable conditions. We pay close attention to vulnerable demographics or roles involving migrant labour, long working hours, or remote work, where risks may be elevated. We also monitor early stages of employment to identify unexpected distress, irregular payments, or signs of coercion.

6.2 EoR Worker Protections

Under our EoR model, GrowMore becomes the legal employer of the worker. This places a higher burden of responsibility on us to ensure their safety and rights. Workers receive written contracts detailing their compensation, working hours, responsibilities, holidays, and termination conditions. Salaries are paid accurately and punctually, and any deductions are lawful and transparent.

Workers retain full control of their identification documents, may leave their role voluntarily, and have unrestricted access to GrowMore for concerns. We conduct checks to ensure accommodation or transport provided by clients meets acceptable living standards.

6.3 Supplier and Vendor Oversight

Before onboarding suppliers or service partners, we verify their legitimacy, assess their labour practices, and review their ethical commitments. Contracts include obligations to comply with anti-slavery standards, provide transparency in their workforce arrangements, and cooperate fully with any investigations or audits.

We monitor suppliers on a risk basis, conducting deeper reviews where their industry, country of operation, or subcontracting model suggests potential exposure to exploitation. If issues arise, suppliers must implement corrective actions immediately.

6.4 Client Due Diligence

Clients play a significant role in ensuring that individuals placed through GrowMore are treated with respect and dignity. We conduct preliminary assessments to understand the client’s operating environment, labour practices, and compliance posture. If a client exposes workers to unethical conditions, GrowMore reserves the right to refuse service or cease activity until concerns are resolved. See our Client Exclusion Policy.

7. Training and Awareness

Effective prevention requires knowledge and awareness. GrowMore provides ongoing training to staff to ensure they recognise risk indicators, understand legal obligations, and know how to respond when concerns arise. Training covers topics such as deceptive recruitment, the vulnerabilities of migrant labour, signs of coercion, and best-practice communication with workers.

We refresh training annually and introduce additional sessions when legislation changes or new risk patterns emerge. Leaders and staff in high-exposure functions (Recruitment, StaffCheck, Vendor Management, EoR) receive enhanced training so they can confidently mitigate risks and support others.

8. Reporting Concerns

GrowMore encourages an environment where individuals feel supported in raising concerns. Workers, employees, and partners may report issues confidentially and without repercussion. We provide multiple reporting channels, including our Legal team which can be contacted on [email protected].

All reports are treated seriously and assessed objectively. We respond swiftly, gather facts, consult external specialists where necessary, and take appropriate action. Retaliation against anyone who raises concerns in good faith is strictly prohibited. We also support individuals in contacting government authorities or international organisations if external escalation is required.

9. Monitoring, Review, and Continuous Improvement

Our commitment to preventing modern slavery is ongoing. We regularly review our processes, vendor performance, and recruitment activities to strengthen protections. This includes analysing patterns of worker complaints, updating due diligence procedures, and incorporating feedback from auditors or industry bodies.

If gaps are identified, we adapt our policies, enhance training, or adjust our partnerships accordingly. We aim to exceed minimum legal requirements by adopting emerging best practice and continuously evolving our standard of care.

10. Policy Breaches

Any breach of this policy is treated with utmost seriousness. Internally, employees who violate the policy may face retraining, disciplinary action, suspension, or termination. Externally, suppliers or clients who fail to uphold their obligations may be suspended, required to undertake remediation, or removed from our partner network entirely. We will notify authorities where criminal behaviour is suspected. Protecting individuals affected by exploitation will always take priority in our decision-making.

11. Approval and Review

This policy is formally approved by the Director. It is reviewed annually, or earlier if legislation evolves, operational risks change, or industry best practice advances. Updated versions are communicated across the organisation and incorporated into training materials where relevant.