Skip to content
AceLeads Jobs

AceLeads legal

Modern slavery statement

Care work and driving work are two of the sectors where labour exploitation in the UK is most often found. A job board sitting between workers and employers in both of them should say what it does about that, whether or not the law makes it.

1. Whether we have to publish this

Section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement from commercial organisations above a turnover threshold set in regulations. HDCH Limited is a small company and is very unlikely to be above it.

We are drafting one anyway. Not because a statement prevents anything by itself, but because writing down which sectors we refuse and which controls exist makes it obvious when one of them quietly stops working.

[NEEDS HUMAN SIGN-OFF] Confirm the current threshold and whether it applies to HDCH Limited. If this is published voluntarily it still has to be approved by the board and signed by a director to be worth anything, and it should be dated and linked from the site footer.

2. Our business, and where the risk sits

We publish job adverts for employers in adult social care and in HGV and logistics driving. We do not employ anyone into those roles, we do not supply workers, and we are not part of the chain between a worker and the business that ends up using their labour.

The risk we can affect is a different one: that our site is used to reach people who are looking for work and are in a weak position. The patterns worth naming are a job advert that is a route to a fee, an advert that leads to work that is not the work described, and an advert placed by a business that is not who it says it is.

3. What we actually do

  • We never charge a work-seeker anything. There is no payment route on this site aimed at a person looking for work, and no code that could create one. A fee charged to a worker for work is one of the most reliable early signals of exploitation, and the simplest way to be certain we are not part of it is to have no mechanism at all.
  • We refuse the licensed sectors outright. Agriculture, horticulture, shellfish gathering, and food and drink processing and packaging are the sectors the Gangmasters and Labour Abuse Authority licenses. We hold no licence, so we do not advertise that work. The check runs on the job rather than the business, so a driving job inside a food processing company is caught.
  • Anything close to the line goes to a person. An advert flagged by that check is never published automatically. It waits for a human decision.
  • Advertisers agree in writing not to charge applicants. It is in the advertiser terms as a condition of advertising, not as a preference.
  • We keep the fraud warning where people will see it, rather than buried in terms nobody opens.

4. What we do not do

Being straight about the gaps is more useful than a list of intentions.

  • We do not inspect workplaces, and we have no visibility of what happens after someone is hired.
  • We do not audit an employer's own labour supply chain.
  • We do not currently verify an advertiser's identity beyond the details it gives us, and deciding what verification to add is an open item.
  • We have no training programme, because there are no employees to train yet. That changes when there are.

[NEEDS HUMAN SIGN-OFF] Advertiser identity checks are the highest value control missing here. Decide what is checked before a first advert goes live, and keep it clear of anything that would amount to taking on employment agency duties.

5. Reporting a concern

If something about an advert on this site worries you, tell us and we will take it down while we look at it, along with everything else from the same advertiser. You do not need to be certain, and you do not need to explain why.

If you think someone is being exploited or forced to work, the Modern Slavery Helpline and the Gangmasters and Labour Abuse Authority both take reports, and either can be contacted without going through us first. In an emergency, the police.

[NEEDS HUMAN SIGN-OFF] Add the current contact details for the helpline and the authority, checked at the date of publication rather than copied from another site, and add our own monitored reporting address once it exists.

6. What happens to this statement

A statement that is written once and never looked at again is worse than none, because it creates the impression of a control. This one is reviewed each year, and it gets rewritten rather than re-dated when what we do changes.