ERSG HOLDINGS LTD

Policies described

Freedom of movement Freedom of association Prohibits any threat of violence, harassment and intimidation Prohibits the use of worker-paid recruitment fees Prohibits compulsory overtime Prohibits child labour Prohibits discrimination Prohibits confiscation of workers' original identification documents Provides access to remedy, compensation and justice for victims of modern slavery

Training described

Your whole organisation Human resources

Worker engagement and working conditions

Your suppliers Workers within your organisation Workers within your supply chain

Social audits

Third party audit arranged by your supplier Unannounced audit

Grievance mechanisms

Using anonymous whistleblowing services, such as a helpline or mobile phone app Through trade unions or other worker representative groups

Other monitoring

Having single points of contact for each supplier so that workers can directly go with concerns and complaints regarding operations.

Demonstrated progress

We refer to progress goals. For example, we have implemented a new compliance portal in the UK to check documents and ensure workers have access to their passports and bank accounts. The next goal is to expand this portal's use across all entities globally so that we can ensure all workers via ERSG are in control of their working practices.

Reported risks and mitigations

• Risk: gangmaster operations where groups of workers are paid via one person's limited company, meaning that a third-party controls the payment.
• Area: Within your supply chains
• Tier: Tier 1 suppliers
• Group: Other vulnerable groups
• Mitigation: We refuse to pay workers via unregistered third parties unless they are wholly compliant, registered umbrella companies that have been properly vetted internally.
• Risk: Client supervision on site being less strict than ERSG would implement internally.
• Area: Our clients for whom we engage workers to provide services.
• Group: Women
• Mitigation: This is a risk of being a recruitment company who is not on site where the work is being performed. To mitigate these risks, we have points of contact for the workers who can be contacted at any time with concerns or issues. These PoCs can then raise the matter with the client without informing them which worker came forward.