Modern Slavery & Human Trafficking Statement Date: 19th January 2026

Modern Slavery Statement Hardhatheads Recruitment Ltd – Modern Slavery and Human Trafficking Statement Financial Year: 2026

Introduction This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Hardhatheads Recruitment Ltd has taken to ensure that modern slavery and human trafficking are not taking place in our business or supply chains.

Our Business Hardhatheads Recruitment Ltd is a specialist recruitment agency operating in the UK infrastructure sector, supplying permanent and temporary workers to clients in Rail, Highways, Civils, and Construction.

Our Policies We are committed to acting ethically and with integrity. Our policies that support this commitment include:

  • Recruitment and Selection Policy: Ensuring all workers are legally entitled to work in the UK and have chosen to work freely

  • Whistleblowing Policy: Encouraging reporting of concerns, including those related to modern slavery

  • Supplier Code of Conduct: Setting expectations for ethical behaviour throughout our supply chain

Due Diligence We undertake due diligence when considering new suppliers and regularly review existing suppliers. This includes:

  • Verifying right to work documentation for all candidates

  • Checking identity documents are genuine

  • Ensuring workers understand their rights, including to receive the National Minimum Wage

  • Confirming bank account details match worker identity

  • Monitoring for signs of exploitation, such as workers appearing controlled or unable to speak for themselves

Risk Assessment Our business involves the supply of temporary labour, which the Gangmasters and Labour Abuse Authority identifies as a higher-risk sector. We mitigate this risk through:

  • Rigorous candidate vetting processes

  • Regular communication with workers to ensure wellbeing

  • Training for all staff on identifying signs of modern slavery

  • Clear reporting channels for concerns

Training All recruitment consultants and relevant staff receive training on:

  • The Modern Slavery Act 2015 and its requirements

  • Indicators of modern slavery and human trafficking

  • Our reporting procedures

  • Ethical recruitment practices

Measuring Effectiveness We measure the effectiveness of our approach through:

  • Number of staff trained on modern slavery awareness

  • Audit findings from right-to-work and compliance checks

  • Reports received and investigated

  • Supply chain assessments completed

Approval This statement has been approved by the Board of Directors of Hardhatheads Recruitment Ltd and will be reviewed and updated annually.