Modern Slavery Act Statement

Current Modern Slavery Act 2015 Statement

As part of our Equal Opportunities Policy and Procedure, Cobalt strives to understand all potential modern slavery risks related to the business.

Cobalt recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensure that its supply chains are free from slavery and human trafficking.

New Modern Slavery Act 2015 Statement for 2020

Organisational Structure

  1. The organisational structure of Cobalt Recruitment (referred to as “The Company”) comprises of offices in five (5) different countries.

  2. Cobalt Recruitment is controlled by a Board of Directors. Cobalt Recruitment’s Head Office is located in London, with other UK offices located in London and Manchester. It also has offices overseas in Singapore, Germany, New Zealand and USA.

  3. Cobalt Recruitment is predominately a leading specialist recruitment provider to the Property, Construction & Engineering and Financial Services & Accounting sectors. We recruit professionals from our offices in the UK, Europe, Asia, America and New Zealand for clients ranging from large corporate organisations to niche entrepreneurial entities, as well as into the public sector. business and legal services to other businesses in both telephone, email and face to face consultancy formats. It offers a 24-hour advisory service for which demand is consistent throughout the year.


Cobalt Recruitment considers that modern slavery encompasses:

  1. Human trafficking– involves transporting, recruiting or harbouring people for the purpose of exploitation, using violence, threats or coercion.

  2. Debt bondage or bonded labour – the world’s most widespread form of slavery, when people borrow money they cannot repay and are required to work to pay off the debt, then losing control over the conditions of both their employment and the debt.

  3. Descent-based slavery – where people are born into slavery because their ancestors were captured and enslaved; they remain in slavery by descent.

  4. Child slavery – many people often confuse child slavery with child labour, but it is much worse. Whilst child labour is harmful for children and hinders their education and development, child slavery occurs when a child is exploited for someone else’s gain. It can include child trafficking, child soldiers, child marriage and child domestic slavery.

  5. Forced labour, through mental or physical threat, against their will

  6. Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;

  7. Being dehumanised, treated as a commodity or being bought or sold as property;

  8. Being physically constrained or to have restriction placed on freedom of movement.

  9. Forced and early marriage – when someone is married against their will and cannot leave the marriage. Most child marriages can be considered slavery.


  1. Cobalt Recruitment acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. Cobalt Recruitment understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.

  2. The labour supplied to Cobalt Recruitment in pursuance of the services it provides is carried out wholly in the countries where those services are provided i.e. United Kingdom, Singapore, Germany, New Zealand and USA as appropriate.

  3. Cobalt Recruitment has a zero tolerance policy towards modern slavery. It will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in servitude, slavery, and forced or compulsory labour.

  4. No labour provided to Cobalt Recruitment in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Cobalt Recruitment strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, Singapore, Germany, New Zealand and USA as appropriate, and in many cases exceeds those minimums in relation to its employees.

  5. Cobalt Recruitment offers employment contracts on a guaranteed hours basis only; no offers of employment are made on a zero hours basis.

  6. Part-time and fixed-term employees within Cobalt Recruitment are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, Cobalt Recruitment is able to rely on objectively justifiable grounds.

  7. Group employees are offered a competitive remuneration package and Cobalt Recruitment prides itself on the additional benefits it is able to offer its employees on a wide variety of platforms. It conducts staff surveys on an anonymous basis to give employees a voice on their individual employment, their department and Cobalt Recruitment company as appropriate. Commitment to creating career progression in a supportive environment has been rewarded by being ranked in the top 100 of the Sunday Times Best 100 Companies to Work for in 2015 and 2016.

Potential Coverage and Steps

  1. Cobalt Recruitment considers its coverage to modern slavery to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

  2. Cobalt Recruitment carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains.

  3. Cobalt Recruitment has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.

  4. Cobalt Recruitment encourages use of its Whistleblowing Policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.

  5. To ensure effectiveness in combatting modern slavery, Cobalt Recruitment maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the Whistleblowing Policy will be responded to in accordance with the policy.

  6. Following a review undertaken for Cobalt Recruitment’s statement of the previous financial year, Cobalt Recruitment confirms its supplier list is up to date for the current financial year.

  7. As in the previous financial year, there have been no reports that any of Cobalt Recruitment’s suppliers have been involved in activities covered by the Modern Slavery Act.


  1. Upon commencement of employment, all employees undergo a structured onboarding process. All employees are made aware of Cobalt Recruitment policies relating to standards of behaviour that it requires from them. Cobalt Recruitment also provides training on awareness of modern slavery to those within Cobalt Recruitment who have been identified as having responsibilities in this regard, namely those involved in finance and procurement. Cobalt Recruitment ensures that annual update training is provided.


A Whistleblowing Policy is in place which encourages the reporting of any wrongdoing which is in the public interest.

Data Protection and Compliance Officer

Cobalt Recruitment has a Group Data Protection & Compliance Officer, to whom all concerns regarding modern slavery should be addressed. Cobalt Recruitment Data Protection & Compliance Officer undertakes an annual review of Cobalt Recruitment’s obligations towards eradicating modern slavery within its organisation and supply chains.


This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and applies to all companies within and associated to Cobalt Recruitment. It is reviewed for each financial year.

This statement relates to the 2018/2019 financial year and was approved by:

James Wakefield, Chief Executive Officer

Sara Burton, Global Operations Director

On 1st January 2020