1. Policy statement 
Kingpin International ("Kingpin") is committed to treating every candidate fairly, lawfully and with dignity, wherever in the world we recruit. We will not tolerate human trafficking, forced labour, exploitation or unfair discrimination at any stage of our recruitment process. 
This policy applies to all of our recruitment work, in every country where we source candidates or place them with clients. Where local law sets a higher standard than this policy, we follow local law. Where this policy sets the higher standard, we follow this policy. 

 

2. Scope 
This policy applies to: 

• all Kingpin directors, employees, contractors and temporary staff; 

• every recruitment activity we carry out, for any client, in any location; 

• any partner agency, sub-agent, referral source or supplier that helps Kingpin source or place 

• candidates. 

 

It covers the full recruitment cycle: advertising, sourcing, screening, interviewing, shortlisting, offer, onboarding support and aftercare. 

 

3. Legal and ethical framework 

• Kingpin is based in the UK and complies with: 

• the Modern Slavery Act 2015; 

• the Equality Act 2010; 

• the Conduct of Employment Agencies and Employment Businesses Regulations 2003; 

• UK GDPR and the Data Protection Act 2018. 

 

When we recruit for roles in other countries, we also comply with the labour, anti-trafficking, anti discrimination and data protection laws of those countries. For example, for roles in Singapore this includes the Prevention of Human Trafficking Act 2014, the Employment Act 1968 and the Tripartite Guidelines on Fair Employment Practices. 
Our practices are also guided by recognised international standards, including: 

• the International Labour Organization (ILO) Forced Labour Convention and its 2014 Protocol; 

• the ILO Private Employment Agencies Convention, which sets out that workers should not be 

• charged fees for finding work; 

• the UN Guiding Principles on Business and Human Rights. 

 

4. Labour rights 
Kingpin will: 

1. Charge candidates nothing. Our fees are paid by clients. We never charge candidates for finding them work and never deduct fees from their pay. 

2. Give honest job information. Before a candidate accepts an offer, we confirm the employer, role, location, salary, working hours, leave and contract length in writing. We do not misrepresent any of these. 

3. Respect freedom of choice. Candidates may decline or withdraw from any role at any time without penalty. 

4. Never hold identity documents. We do not retain passports, visas, ID cards or qualification certificates. We keep copies only where needed for lawful checks.

5. Give accurate immigration information. We give candidates correct information about the right to work in the country concerned and do not encourage anyone to work without the required permission.

6. Protect personal data. Candidate data is handled in line with UK GDPR and the data protection laws of the countries we work in and shared with clients only for the role applied for.

 

5. Preventing human trafficking and forced labour

Kingpin has zero tolerance of human trafficking, forced or bonded labour, debt bondage and any form of modern slavery.

To prevent it, we:

• verify the identity and legitimacy of every client before placing candidates with them;

• speak to candidates directly, not only through third parties, to confirm they are applying freely;

• watch for warning signs, such as a third party controlling a candidate's documents, contact details, money or movements, or a candidate reporting debts owed to a recruiter;

• stop the process immediately and escalate to the Compliance Lead if we suspect exploitation;

• report credible concerns to the relevant authorities, including the police in the country concerned and, in the UK, the Modern Slavery Helpline.

 

Kingpin will end any relationship with a client, partner or supplier found to be involved in trafficking or forced labour.

 

6. Fair employment practices

Kingpin assesses every candidate on merit: skills, experience, qualifications and ability to do the job. We do not discriminate on the grounds of age, nationality, sex, gender reassignment, sexual orientation, marital or civil partnership status, pregnancy or maternity, caregiving responsibilities, race, religion or belief, language, disability or mental health condition.

In practice, we:

• write job adverts that state the real requirements of the role and avoid discriminatory wording, such as "young" or "male preferred", unless the client shows it is a genuine occupational requirement that is lawful in that country;

• use consistent screening criteria for every candidate on the same role;

• decline or challenge client instructions that would require unlawful discrimination;

• respect local rules that require fair consideration of local candidates.

 

7. Partners and sub-agents

• Before working with any partner, sub-agent or referral source, Kingpin will:

• check that they hold any licence required for the work they do;

• require written agreement to the standards in this policy;

• confirm they charge candidates no unlawful fees;

• review the relationship at least once a year.

 

Kingpin will not use unlicensed intermediaries where a licence is required.

 

8. Reporting concerns

Anyone can report a concern about Kingpin's recruitment practices, including candidates, clients, partners, staff and members of the public. Reports can be made anonymously.

How to report

• Email: confidential @ stafffinders.co.uk

• In writing: Compliance Lead, Kingpin International, 6 New Street, Paisley, PA1 1XY

 

What happens next

1. We acknowledge the report within 2 working days, where contact details are given.

2. The Compliance Lead reviews it and, where needed, opens an investigation.

3. We aim to complete the investigation within 30 days and tell the reporter the outcome, where appropriate.

4. Where a report suggests trafficking, forced labour or a risk to someone's safety, we act immediately and contact the relevant authorities.

 

No retaliation

Kingpin will not penalise, dismiss, blacklist or treat unfairly anyone who raises a concern in good faith, even if it turns out to be unfounded. Reports are kept confidential and shared only with those who need to know to investigate.

 

9. Responsibilities, training and review

Responsibilities. The Board of Directors owns this policy. The Compliance Lead, Tamlin Roberts, is responsible for putting it into practice, handling reports and keeping records. Every member of staff is responsible for following it.

 

Training. All staff receive training on this policy when they join and a refresher every year.

 

Breaches. A breach of this policy by staff may lead to disciplinary action, up to and including dismissal. A breach by a client, partner or supplier may lead to the relationship ending. Review. This policy is reviewed every year, and sooner if the law changes in any country where we work.

 

Approved by: Jane Wylie-Roberts, Director

​