Modern Slavery Statement

INTRODUCTION

Section 54 of the Modern Slavery Act 2015 (“the Act”) requires commercial organisations supplying goods or services, carrying on business in the UK, and with an annual turnover of £36 million or above, to publish an annual modern slavery and human trafficking statement.

Glu Recruit Ltd (“Glu Recruit”, “we”, “our”) has an annual turnover below £36 million and is therefore not legally required to publish a statement under the Act. However, we voluntarily publish this Modern Slavery and Human Trafficking Policy and Statement to demonstrate our ongoing commitment to ethical business practices and to set out the steps we take to prevent modern slavery and human trafficking within our business operations and supply chains.

We recognise that modern slavery is a serious global issue and are committed to acting transparently, responsibly, and with integrity in all our business relationships.

STRUCTURE AND SUPPLY CHAINS

Glu Recruit is a specialist recruitment agency providing permanent and temporary recruitment solutions across Yorkshire and the Midlands, placing candidates into a wide range of professional, office-based, sales, and creative roles.

Our permanent workforce consists of office-based recruitment consultants and administrative staff operating from our offices in Rotherham. In addition, we recruit, engage, and supply temporary agency workers to client organisations across multiple sectors.

Our supply chain primarily consists of goods and services that support our recruitment operations, including but not limited to:

• Training and professional development providers
• IT systems and support services
• Payroll and umbrella services
• Facilities management and utilities
• Marketing, compliance, and professional services

We recognise that the recruitment sector carries inherent risks relating to modern slavery, particularly where temporary labour is involved, and we take these risks seriously.

DUE DILIGENCE AND RISK ASSESSMENT

We assess the risk of modern slavery and human trafficking within our business and supply chains on an ongoing basis. Key risk factors include high worker turnover, reliance on digital processes, and limited face-to-face interaction in some recruitment activities.

To mitigate these risks, we operate robust due diligence and compliance procedures, including:

• Verifying the identity and right to work of all candidates prior to placement, in line with current UK legislation
• Collecting and securely storing identification documentation, including proof of address and date of birth
• Using secure digital systems to cross-check applicant information for inconsistencies or suspicious patterns (such as repeated addresses, contact details, or bank information)

Additional safeguards include:

• Conducting interviews with candidates (in person or via secure video platforms)
• Confirming how candidates became aware of Glu Recruit and applied for roles
• Communicating directly with candidates and not through unauthorised third parties
• Investigating and escalating any concerns relating to unusual payment instructions or third-party bank accounts

To manage risks within our supply chain, we:

• Engage with suppliers to understand their approach to preventing modern slavery and human trafficking
• Encourage suppliers to maintain appropriate policies and controls
• Where appropriate, include anti-slavery and human trafficking clauses in supplier contracts
• Periodically review supplier relationships based on risk, scale, and service provided

POLICIES AND STAFF TRAINING

Our commitment to combating modern slavery and human trafficking is supported by a suite of internal policies and procedures, including but not limited to:

• Whistleblowing Policy
• Anti-Bribery and Corruption Policy
• Equality, Diversity and Inclusion Policy
• Data Protection and Information Security Policies

These policies promote ethical conduct, transparency, and accountability across all areas of our business. Employees are encouraged and supported to raise concerns confidentially, without fear of retaliation.

All employees receive training relevant to their role on:

• Recognising indicators of modern slavery and human trafficking
• Our legal and ethical responsibilities
• How to report concerns internally and, where appropriate, externally

The Managing Director holds overall responsibility for ensuring that policies, procedures, and training relating to modern slavery remain up to date and effective.

MEASURING EFFECTIVENESS

To date, Glu Recruit has not identified or reported any confirmed incidents of modern slavery or human trafficking within its business or supply chains.

We recognise, however, that absence of evidence does not equate to absence of risk. We therefore remain vigilant and committed to continuous improvement by:

• Reviewing policies and procedures annually
• Monitoring recruitment practices and supplier relationships
• Encouraging feedback and reporting from employees, candidates, and suppliers

FURTHER STEPS

We will continue to strengthen our approach to preventing modern slavery and human trafficking by:

• Periodically reviewing our due diligence and risk assessment processes
• Enhancing training content as guidance and risks evolve
• Reviewing actions where there is reasonable suspicion of modern slavery or human trafficking, including:
• Reporting concerns to appropriate authorities where required
• Reviewing and strengthening internal controls following any investigation
• Conducting a formal review of this statement at least every five years, or sooner if required by changes in legislation, business structure, or risk profile

APPROVAL OF THIS STATEMENT

This Modern Slavery and Human Trafficking Policy and Statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 on a voluntary basis.

It was approved by the Managing Director in January 2026 and applies to the financial year ending 30 June 2025 and beyond.

Signed on behalf of Glu Recruit Ltd:

Robert Shaw

Managing Director
January 2026