Modern Slavery Policy


This Modern Slavery and Human Trafficking Statement is a response to Section 54(1),Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 13 March 2023. 

Starget t/a Hirer Ltd (‘Starget’, ‘the Company', 'we', 'us' or 'our') is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values. 

Organisational Structure

Starget has business operations in the United Kingdom, as well as:

·    Thailand

·    Vietnam

·    Philippines

·    European Union

·    Isle of Man

We operate in the recruitment advertising sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers, who provide us with services, such as job site advertising, IT software, marketing services, and outsourced business processes.

 For more information about the Company, please visit our website:


We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. 

 These include the following:

·    Recruitment and selection policy - We conduct checks on all prospective employees to verify that they are eligible to work in the UK. When working with overseas employees we verify their credentials.

·    Supplier code of conduct - We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.

·    Staff code of conduct - We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.

·    Procurement policy - We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains. Our procurement policy and supporting procedures set out controls and check sunder taken to help verify this.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures: 

·    Internal supplier audits.

Our due diligence procedures aim to:

·    Identify and action potential risks in our business and supply chains.

·    Monitor potential risks in our business and supply chains

·    Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and Compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

·    Evaluating the slavery and human trafficking risks of each new supplier.

We do not consider that we operate in a high-risk environment because the business operates in this risk level environment because the majority of our supply chain is based in the UK and in low-risk industries such as internet software and services. Where we operate outside the UK, we have chosen countries of a low risk and that have protection for human rights and contract workers. Moreover, our financial transactions are conducted in a manner that reduces the risk of money laundering.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.


The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

·    We will contact suppliers to enquire about their modern slavery practices every 24 months.

·    We will train our staff about modern slavery issues and increase awareness within the Company.

Training Staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company's training covers: 

·    How to identify the signs of slavery and human trafficking.

·    What initial steps should be taken if slavery or human trafficking is suspected.

·    How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.

The statement was approved by the board of directors.

Date 11 December2023