This Modern Slavery and Human Trafficking Statement relates to actions and activities for Frontier Consulting Ltd during the financial year 01^st October 2022 to 30^th September 2023.

The statement sets down Frontier Consulting Ltd commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational Structure and Supply Chains

This statement covers the business activities of Frontier Consulting Ltd which are as follows:

Frontier Consulting is a Private Limited Company operating as an Employment Business providing the specialist supply of Permanent/International Permanent, Temporary, and Interim, staffing solutions to the Health & Social Care sector. This includes Local Authority, NHS, and Private Sector bodies/organisations. Engagements for the provision of Temporary and/or Interim Workers are either direct with the end Client, or via a Framework, Neutral Vendor, or Master Vendor contract arrangement. The Temporary/Interim Worker assignment is facilitated either directly by Frontier Consulting as an employee, or via an Umbrella Service, or a Personal Service Company.

The Company currently services the entire UK, in addition to providing Permanent International Recruitment Services to Australia. All Permanent staff sourced and provided to work in either the UK or Australia are vetted to ensure correct work and residency eligibility is in place. All Temporary Staff supplied hold residency and work eligibility within the UK.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to attend an Induction upon employment, which outlines expectations and responsibilities in relation to Modern Slavery and Human Trafficking and are actively encouraged to bring any suspicions or concerns to the attention of Frontier Consulting’s Senior Management. Refresher training is conducted throughout the course of the year and upon receipt of relevant legislative updates.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships. Frontier Consulting believe that all staff have a responsibility to uphold the Companies anti-slavery initiatives and operate in line with our policies and procedures to mitigate such practices.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

• Modern Slavery Policy – the Company holds a Modern Slavery Policy which outlines our ‘zero tolerance’ approach to breaches and/or suspected breaches of the Modern Slavery Act 2015, and the expectation of all employees to adhere to this
• Whistle-blowing Policy – the Company encourages all it’s workers, customers and other business partners to report any concerns related to its direct activities or its supply chain
• Company Code of Conduct – the Code of Conduct sets out the actions and behavior expected of employees when representing the Company
• Contract Arrangements – as part of our contracting process we include specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude
• Safeguarding Policy – our Policy outlines our commitment to the protection of vulnerable Adults and Children
• Accurate Charge, Invoice, and Processing Policy – all payment transactions are audited and cross-matched with invoices to ensure correct payments to the supplier and the worker, including regular auditing to ensure adherence to Minimum Wage obligations and the Criminal Finance Act 2017

In February 2020 Frontier Consulting implemented the following additional policy to further strengthen our steps and commitment to upholding the prevention of slavery and human trafficking within our operations and supply chain:

• Corporate & Social Responsibility Policy – further outlines our goals and commitment to operate in conjunction with our relevant industry-specific Policies, including our Modern Slavery, Equality & Diversity, Quality Assurance, and Accurate Charge, Process & Invoice Policies, in order to achieve ethical business objectives and growth

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. As a business within the Recruitment Sector several process already exist which are required either by law or best practice that assist in the identification and mitigation of the risk of Modern Slavery within or organization and supply chains. This due diligence process includes:

• Relevant industry compliance checks, including ID verification, comprehensive work history and subsequent reference checks, and confirmation of eligibility to work in the UK
• Building long-standing relationships with suppliers and making clear our expectations of business partners
• Outlining our stance in relation to Human Trafficking and Modern Slavery risks, and incorporating such prohibitions within our contracting process with each supplier
• Continuous review of our internal processes and modification if/where necessary to ensure compliance and minimize risk

The COVID-19 pandemic led to several short-to-medium-term changes across various aspects of the UK Health & Social Care Staffing Sector in which Frontier Consulting operates. Prominently, the demand for frontline professionals increased, whilst concessions within sector compliance requirements were implemented by the UK Government, NHS England & NHS Improvement, and associated Regulatory Bodies, to address and achieve the required staffing levels. Frontier Consulting recognized the short-notice implementation of these factors as a potential opportunity for Slavery and Human Trafficking to be exploited and subsequently increased the frequency and subsequent due-diligence of our internal audits, whilst responding to our external sector supply chain audit obligations. Following this, no significant risk of breach to the Modern Slavery Act 2015 and/or Human Trafficking within our current supply chain has been identified.

We continue to be vigilant and have reviewed and amended the following to assist with this:

• Whistle-blowing Policy
• Employee Handbook
• Agency Worker Handbook
• Arrangements for Temporary/Interim Workers to facilitate assignment
• Audit frequency, including trigger-points

It remains that only members of Frontier Consulting’s Senior Management Team are authorized to enter contracts and commercial relationships, having fully vetted and ratified the potential for risk. To strengthen and ensure adherence and application of the relevant process to combat Modern Slavery, Frontier Consulting engages with external Human Resource and Legal Services and Regulatory Bodies. Any suspicions or complaints relating to Modern Slavery raised with Frontier Consulting are investigated thoroughly and in accordance with our Complaints Procedure.

Overall responsibility to ensure the steps taken to combat Modern Slavery and Human Trafficking resides with Frontier Consulting’s CEO. All initial enquiries or comments relating to this statement should be directed to Gareth Welch, Commercial Director, at gwelch@frontierconsulting.com

Performance Indicators

Frontier Consulting monitor various elements of our commercial engagements to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains. These include:

• The engagement of Umbrella Companies for payment processing by Temporary Workers, including those not possessing industry accreditation
• The source and frequency of any referrals (business or personal)
• The source and frequency of requests for specific temporary workers

Audits are conducted with regularity and any anomalies or causes for concern investigated thoroughly.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary.Frontier Consulting’s Board of Directors and Senior Management Team endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by Frontier Consulting’s Board of Directors.