01Our commitment
The Oyster Partnership Limited (“Oyster”, “we”, “our”) has a zero tolerance approach to modern slavery, servitude, forced or compulsory labour and human trafficking in any form. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chain.
As a recruitment business placing people into work, we recognise that our sector carries a specific and heightened responsibility. Labour exploitation is one of the most common forms of modern slavery in the UK, and employment agencies and employment businesses are a route through which it can occur. This statement sets out the steps we have taken during the financial year to prevent that.
02Our organisation and business
Oyster is a privately owned recruitment consultancy headquartered at 19-20 Berners Street, Bischheim House, London W1T 3NW (company number 05020374). We employ around 62 people from a single UK office and operate exclusively within the United Kingdom.
We provide permanent and temporary (contract) recruitment services, primarily to the UK public sector and its partners: local authorities, housing associations, NHS bodies, regulators and private sector organisations delivering public services. Our specialisms include housing, property, planning, building control, surveying, environmental health, regulatory services and corporate functions. We also deliver managed and outsourced service contracts where our workers perform a service on a client’s behalf.
We are registered with the Information Commissioner’s Office (ZA094096), operate under the Conduct of Employment Agencies and Employment Businesses Regulations 2003, and are subject to inspection by the Employment Agency Standards Inspectorate.
03Our supply chain
Our supply chain is short and predominantly UK based, which limits but does not remove our exposure. The areas of it that carry modern slavery risk are:
- Temporary workers. The contractors and agency workers we supply to clients, who are engaged through PAYE, their own limited companies, or umbrella companies.
- Umbrella companies and payroll intermediaries. Third parties that employ and pay some of our contractors. This is the highest risk part of our supply chain, because payroll intermediaries have been used elsewhere in the sector to withhold wages, charge unlawful fees or control workers’ bank accounts.
- Recruitment supply partners. Occasionally, other agencies who supply candidates to us under a second tier arrangement.
- Business services. Office premises and facilities, IT and software providers, professional advisers, marketing and events suppliers. These are low risk, established UK or international providers.
04Our policies
The following policies support our approach and are available to all staff:
| Policy | How it supports this statement |
|---|---|
| Modern Slavery Policy | Sets out our zero tolerance position, the warning signs staff must look for, and how to escalate a concern. |
| Whistleblowing Policy | Protects any employee, worker or supplier who raises a concern in good faith, including concerns about exploitation of a candidate or worker. |
| Recruitment and Candidate Compliance Procedure | Requires identity and right to work verification for every worker before placement, and prohibits any fee being charged to a work seeker for finding them work (Conduct Regulations 2003, reg. 5). |
| Supplier and Umbrella Company Due Diligence | Sets the minimum standards a payroll intermediary must meet before we will engage with it, and the checks we repeat annually. |
| Anti-Bribery and Corruption Policy | Ensures we do not engage in or tolerate corrupt practices that could enable exploitation. |
| Equal Opportunities Policy | Commits us to fair and lawful treatment of all candidates and workers regardless of nationality or background. |
| Customer Care and Complaints Policy | Gives candidates, workers and clients a clear route to raise a complaint about their treatment. |
05Due diligence and risk management
5.1 Workers we place
- Every worker’s identity and right to work in the UK is verified before they start an assignment, using original documents, the Home Office online service or an IDVT-certified provider. We do not accept documents supplied through a third party on a worker’s behalf.
- We interview every worker directly and confirm that they are applying of their own free will, understand the terms of the assignment and have not paid anyone to obtain the work.
- Pay is only ever made to a bank account in the worker’s own name. We monitor for indicators of control, including multiple workers registering the same bank account, address, phone number or email, and investigate any match.
- We never charge a work seeker a fee for finding them work and never make an engagement conditional on a worker purchasing any other service.
- Every temporary worker receives a written statement of terms, including their rate of pay, before starting an assignment, and pay is reconciled against approved timesheets.
5.2 Umbrella companies and intermediaries
- We only engage umbrella companies that hold a recognised accreditation (FCSA or Professional Passport), and we hold a copy of their accreditation, their own modern slavery statement or policy, and their payslip example on file.
- Contractors are free to choose whether to be paid via PAYE, their own limited company or an umbrella. We do not mandate a single provider and do not receive incentives from any provider.
- Umbrella providers are reviewed annually and we reserve the right to audit their payment records for our workers. We monitor HMRC’s published list of named tax avoidance schemes and will remove any provider that appears on it.
5.3 Other suppliers
- Our standard terms of business require suppliers to comply with the Modern Slavery Act 2015 and all applicable employment law, and give us the right to terminate on breach.
- New suppliers with a material labour component are assessed for modern slavery risk before engagement.
5.4 Risk assessment
We assess our overall modern slavery risk as low, on the basis of our UK only operations, the professional and skilled nature of most roles we fill, our direct relationship with every worker, and our accredited only umbrella policy. We recognise the risk is higher for lower paid and operational roles, for workers with limited English or recently arrived in the UK, and wherever a third party sits between us and the worker’s pay. Our controls are weighted accordingly.
06Training and awareness
All client facing consultants and compliance staff receive modern slavery awareness training at induction as part of the Oyster Academy programme, and refresher training at least annually. Training covers the definitions and indicators of modern slavery, the specific risks in recruitment, how to respond if a worker discloses exploitation, and how to report concerns internally, to the Gangmasters and Labour Abuse Authority (GLAA) or via the Modern Slavery and Exploitation Helpline (08000 121 700).
07Measuring effectiveness
We monitor the following indicators to assess the effectiveness of our approach:
| Indicator | Position for the year |
|---|---|
| Workers placed without a completed right to work check | None |
| Payments made to a bank account not in the worker’s own name | None |
| Umbrella providers engaged without a recognised accreditation | None |
08Plans for the coming year
- Refresh our Modern Slavery Policy and staff training to reflect the Employment Rights Act 2025 provisions on umbrella company regulation and the new Fair Work Agency, as they come into force.
- Extend our supplier questionnaire to all suppliers with a labour component, not only payroll intermediaries.
- Add modern slavery indicators to our compliance dashboard so they are reviewed monthly, not annually.
09Approval
This statement was approved by the Board of Directors of The Oyster Partnership Limited and will be reviewed and updated annually.