Nexus Spark Group
Effective date: 1st October 2026
Review date: 1st October 2027
1. Policy Statement
Nexus Spark Group is committed to conducting business ethically, responsibly and with integrity.
We have a zero-tolerance approach to modern slavery, human trafficking, forced labour, servitude and exploitation within our own business and within the recruitment and supply chains in which we operate.
As a recruitment business, we recognise our responsibility to protect candidates and workers from exploitation and to work with clients, suppliers and other partners who share appropriate standards of ethical conduct.
This policy sets out the principles and procedures Nexus Spark Group follows to identify, prevent and respond to risks relating to modern slavery and human trafficking.
2. About Nexus Spark Group
Nexus Spark Group is a UK recruitment business specialising in Data and AI talent.
We support clients with the identification, assessment and recruitment of talent, including permanent and contract recruitment.
Our activities may involve relationships with:
- Candidates and work-seekers.
- Contractors and temporary workers.
- Client organisations and hiring managers.
- Payroll, umbrella and employment intermediaries where applicable.
- Technology and professional service suppliers.
- Other third parties involved in the recruitment and employment supply chain.
We recognise that recruitment businesses have an important role in ensuring that individuals seeking work are treated fairly and are not exposed to coercion, exploitation or deceptive recruitment practices.
3. What We Mean by Modern Slavery
Modern slavery is a serious crime and violation of fundamental human rights.
It can include:
- Slavery and servitude.
- Forced or compulsory labour.
- Human trafficking.
- Labour exploitation.
- Debt bondage.
- Coercion or threats connected with employment.
- The withholding of identity documents or wages as a means of control.
- Deceptive recruitment practices intended to exploit workers.
Nexus Spark Group will not knowingly participate in, facilitate or benefit from any form of modern slavery or human trafficking.
4. Recruitment Practices
Nexus Spark Group is committed to operating a transparent and ethical recruitment process.
We will:
- Not charge candidates or work-seekers fees for finding them employment where prohibited by law.
- Provide candidates with accurate information about roles, clients and assignments to the extent reasonably available to us.
- Avoid knowingly making misleading representations regarding pay, working conditions, location or the nature of a position.
- Undertake appropriate identity and right-to-work checks where these are our responsibility.
- Take reasonable steps to ensure candidates understand the arrangements under which they will work.
- Never knowingly retain a candidate’s passport or original identity documentation as a condition of finding or continuing work.
- Not knowingly place an individual in circumstances where there are reasonable grounds to suspect forced labour, trafficking or exploitation.
- Treat candidates fairly regardless of nationality or employment status and remain alert to circumstances that may make an individual vulnerable to exploitation.
Where Nexus Spark Group operates as an employment business or supplies contractors, additional checks may be undertaken on the parties involved in the contractual and payment chain.
5. Clients
Nexus Spark Group expects the clients we work with to comply with applicable employment, labour and modern slavery legislation.
Where appropriate, we may seek information from clients regarding:
- The nature and location of the work.
- Working conditions.
- Pay or remuneration.
- Working hours.
- Health and safety.
- The identity of the organisation engaging the worker.
- Any intermediaries involved in the engagement.
- Other information reasonably required to understand the assignment and protect the work-seeker.
If Nexus Spark Group becomes aware of credible information suggesting that a client or workplace may be involved in modern slavery, forced labour or serious worker exploitation, we will investigate the circumstances within the limits of our role.
We reserve the right to decline, suspend or terminate a business relationship where serious concerns cannot be satisfactorily addressed.
6. Contractors and Labour Supply Chains
Contract recruitment can involve additional parties between the individual performing the work and the end client.
Where relevant, these may include personal service companies, umbrella companies, payroll providers, managed service providers and other recruitment businesses.
Nexus Spark Group will take proportionate steps to understand the contractual supply chain through which workers are engaged and paid.
Where we use or approve third-party employment or payroll providers, we may undertake checks appropriate to the nature and level of risk presented by that relationship.
Nexus Spark Group will not knowingly participate in arrangements designed to exploit workers or disguise unlawful employment practices.
7. Suppliers and Business Partners
We expect suppliers and business partners to conduct their businesses ethically and comply with applicable modern slavery, employment and human trafficking legislation.
Our level of due diligence will be proportionate to the nature of the supplier, the services provided and the potential level of risk.
Where appropriate, Nexus Spark Group may:
- Review information about a supplier or intermediary.
- Request confirmation of relevant policies or compliance procedures.
- Review contractual arrangements.
- Investigate credible concerns raised about working practices.
- Refuse to work with organisations where material concerns cannot be resolved.
8. Identifying Potential Modern Slavery
Anyone working for or with Nexus Spark Group should remain alert to potential indicators of exploitation.
These can include situations where an individual:
- Appears to be under the control of another person.
- Is unable to speak freely about their employment arrangements.
- Does not appear to have possession or control of their own identification documents.
- Has been charged unexplained or excessive recruitment-related fees.
- Appears to have been deceived about the nature, location or remuneration of their work.
- Is subject to threats, intimidation or coercion.
- Has wages withheld without legitimate reason.
- Appears unable to leave their employment freely.
- Is working in conditions materially different from those originally represented to them.
The presence of an individual indicator does not necessarily establish that modern slavery is occurring. Concerns should nevertheless be taken seriously and considered appropriately.
9. Reporting Concerns
Nexus Spark Group encourages candidates, contractors, employees, clients and suppliers to raise concerns about suspected modern slavery or unethical working practices.
Concerns should be reported to:
Nexus Spark Group
Website: www.nexusspark.co.uk
Email: charlie@nexusspark.co.uk
Contact: Charlie W-White
Concerns will be treated seriously and handled as confidentially as reasonably possible.
No person should suffer detrimental treatment for raising a genuine concern in good faith.
Where there is evidence or a reasonable suspicion that criminal activity or modern slavery may be occurring, Nexus Spark Group may refer the matter to the appropriate authorities.
Where there is an immediate risk to an individual’s safety, the emergency services should be contacted.
10. Due Diligence and Risk Management
Nexus Spark Group adopts a risk-based and proportionate approach to modern slavery.
Our controls may include:
- Candidate identification and eligibility checks.
- Obtaining appropriate information about roles and assignments.
- Reviewing unusual employment or payment arrangements.
- Conducting appropriate checks on employment intermediaries.
- Monitoring concerns or complaints from candidates and contractors.
- Reviewing higher-risk supply arrangements where appropriate.
- Escalating suspected exploitation to a Director.
Particular attention will be given to situations where complex labour supply chains, unusual deductions, third-party control of workers or other circumstances create an increased risk of exploitation.
11. Responsibility for this Policy
The Directors of Nexus Spark Group have overall responsibility for this policy and for ensuring that appropriate measures are maintained within the business.
Everyone working on behalf of Nexus Spark Group is expected to understand and comply with the principles contained within this policy.
Any breach or suspected breach should be reported to a Director.
12. Breaches
Nexus Spark Group may terminate or suspend relationships with suppliers, intermediaries, clients or other business partners where there is credible evidence of involvement in modern slavery, human trafficking or serious labour exploitation.
Any employee or representative of Nexus Spark Group found to have knowingly participated in or ignored such practices may also be subject to appropriate action.
Where appropriate, suspected criminal conduct will be reported to the relevant authorities.
13. Continuous Improvement
Nexus Spark Group recognises that preventing modern slavery requires ongoing vigilance.
We will periodically review our recruitment processes, contractor supply chains, supplier relationships and internal controls and make improvements where new risks or regulatory requirements are identified.
14. Review and Approval
This policy will be reviewed at least annually, or sooner where there is a significant change to Nexus Spark Groups business model, recruitment activities, supply chain or relevant legislation.