MODERN SLAVERY & HUMAN TRAFFICKING STATEMENT

GWV Talent Solutions Limited: financial year ending 30th March 2026

1. Introduction and scope

This statement sets out the steps GWV Talent Solutions Limited has taken during the financial year ending April 2026 to identify, prevent and address modern slavery and human trafficking in our business and supply chains. It is published under section 54 of the Modern Slavery Act 2015 on a voluntary basis.

This statement covers GWV Talent Solutions Limited (company number 04486902), which trades as Gerrard White and Vermelo RPO.

We recognise that modern slavery risks exist across the recruitment and temporary labour sector, including in professional sectors. Our approach is to identify where those risks arise in our business, put proportionate controls in place, and improve them each year.

2. What we mean by modern slavery

Modern slavery is a serious crime. The Modern Slavery Act 2015 covers the following offences:

  • Slavery: exercising powers of ownership over a person.

  • Servitude: a coerced obligation to provide services.

  • Forced or compulsory labour: work or services exacted under the threat of a penalty, which the person has not offered voluntarily.

  • Human trafficking: arranging or facilitating the travel of another person with a view to exploiting them.

3. Our structure, business and supply chains

GWV Talent Solutions Limited is a UK company based at 16 Lonsdale Gardens, Tunbridge Wells, Kent. It operates as both an employment business and an employment agency through two brands:

  • Gerrard White: permanent, contract and temporary recruitment in the insurance, financial, legal and technology sectors.

  • Vermelo RPO: recruitment process outsourcing (RPO), managed service provision (MSP), Recruiter-as-a-Service (RaaS) and payroll services.

Our main supply chains are:

  • the candidates, contractors and temporary workers we place with or supply to clients;

  • umbrella companies and other payment intermediaries through which some contractors are paid;

  • payroll, background screening and technology providers that support our services;

  • general office goods and services; and

  • recruitment support services provided by a supplier based in South Africa, who carry out candidate sourcing, CV screening, administration on behalf of Vermelo RPO.

4. Our modern slavery risks

The professional sectors we recruit for are generally lower risk than sectors such as construction, logistics, hospitality or care. Lower risk is not no risk. The risks we consider most relevant to our business are:

  • Workers paid through third parties: where contractors are paid through umbrella companies or other intermediaries, there is a risk of unlawful deductions, withheld pay or a third party controlling a worker's earnings.

  • Identity and right to work: a risk that a person is put forward for work using false or borrowed documents, or under the control of someone else.

  • Workers on client sites: once a worker is placed, we have less direct visibility of how they are treated day to day.

  • Supplier practices: risks further down our supply chain, for example in cleaning, facilities or offshore support services, where these are used.

We assess these risks annually. Our most recent assessment was completed on 9th October 2026.

5. Our policies

Our commitment is supported by the following policies and procedures.

  • POL6 Whistleblowing Policy

  • POL39 Right to Work and Candidate Verification Policy

  • Umbrella Company Compliance Processing Procedure

  • POL2 Anti-Bribery Policy

6. Due diligence and controls

Candidates and workers

  • We carry out right to work and identity checks before a candidate starts a temporary or contract assignment.

  • We do not charge work-seekers fees for finding them work, in line with the Conduct of Employment Agencies and Employment Businesses Regulations 2003.

  • Our consultants look for warning signs at registration and during assignments.

Umbrella companies and payroll

  • We work only with umbrella companies and third-party providers that are compliant, including only those that are FCSA-accredited.

  • Since 6 April 2026, agencies can be jointly and severally liable for unpaid PAYE where an umbrella company is used in the supply chain. We have reviewed our umbrella arrangements in light of this. We are also monitoring the planned regulation of umbrella companies under the Employment Rights Act 2025.

Suppliers

  • We carry out due diligence before onboarding suppliers.

7. Training

All employees receive training on recognising the signs of modern slavery, including forced labour, trafficking and servitude. Directors are trained to respond to concerns appropriately. Consultants receive additional guidance on the warning signs most relevant to recruitment.

8. Monitoring and Review

This statement and our internal policies are reviewed annually to ensure continued effectiveness and compliance with legal obligations. Risk assessments, staff training, and supplier checks are ongoing components of our anti-slavery approach.

9. Reporting concerns

Employees, candidates, workers and suppliers can raise concerns about exploitation, whether within GWV Talent Solutions Limited or in our supply chains, with any Director or through our Whistleblowing Policy. All concerns are taken seriously, and no one raising a concern in good faith will suffer any detriment for doing so.

If we identify a potential victim of modern slavery, our first priority is their safety. We will immediately make a referral to the police or the helpline and provide support for the individual.  Anyone can also contact the Modern Slavery & Exploitation Helpline on 08000 121 700 or report online at www.modernslaveryhelpline.org.

10. Approval

This statement was approved by the Board of Directors of GWV Talent Solutions Limited on 09/10/2026. It will be reviewed annually and updated as necessary.

It is published on our website www.gerrardwhite.com and www.vermelorpo.com.

Approved by Anthony Butler, Managing Director, GWV Talent Solutions Limited

Date: 09/10/2026