Modern Slavery and Human Trafficking Statement
Statement period: [Year of publication — populate on Tony approval]
Published: [Date — populate on Tony approval]
About this statement
This statement is published voluntarily by Tony Pugal Recruitment Ltd (Companies House 06879773) in line with the spirit of the Modern Slavery Act 2015. The agency operates below the £36 million turnover threshold at which a statement becomes legally mandatory, but recognises that the recruitment sector — and the industrial-temp segment in particular — is a high-risk environment for modern slavery and human trafficking offences. We publish this statement to signal our position to clients, candidates, suppliers, and the wider public.
Our business
Tony Pugal Recruitment is an owner-led industrial staffing agency based in Leeds, West Yorkshire. Founded in November 1988, we place temporary and permanent workers into manufacturing, warehousing, distribution, and light-industrial roles across Leeds and West Yorkshire. The agency is led by founder Tony Pugal and has no other recruitment consultants. All worker engagement, vetting, and placement passes through the founder personally.
Our supply chains
The agency's supply chain is short and tightly bounded:
- Workers: sourced directly from local Leeds and West Yorkshire candidates, returning workers known to the founder, and walk-in registrations at Oxford House, Leeds.
- Client employers: manufacturing, warehouse, and distribution sites across Leeds and West Yorkshire, the majority of whom we have worked with for ten years or more.
- Service providers: office hosting, accountancy, payroll software, and IT.
The agency does not use sub-contractors to source workers. The agency does not operate offshore. The agency does not work with brokers, intermediaries, or labour providers outside its own direct candidate pool.
Our policies and controls
Our position on modern slavery and human trafficking is supported by the following controls, which the founder operates personally:
- Right-to-work checks are completed for every worker before any placement. Workers without verified right-to-work documentation cannot start a shift through this agency.
- Direct interview — every worker meets the founder either in person at Oxford House or on a recorded telephone call before any placement. We do not place workers we have not spoken with directly.
- Wage transparency — workers are informed of their hourly rate and pay arrangements before they accept a placement. There are no deductions for accommodation, transport, or kit. Wages are paid directly to the worker's nominated bank account, never to a third party.
- AWR week-12 pay parity is applied per the Agency Workers Regulations 2010.
- Client vetting — we work only with established Leeds and West Yorkshire employers known to the founder. We do not on-board client employers without site visits or pre-existing reference history.
- Reporting channel — any worker, client, or member of the public concerned about modern slavery or human trafficking issues at sites we supply can contact the founder directly on 0113 226 1111 or tony@tonypugalrecruitment.co.uk.
Risk assessment
The agency assesses its modern slavery and trafficking risk profile as follows:
- Sector risk: the industrial-temp segment is recognised as elevated-risk by the Gangmasters and Labour Abuse Authority and the Fair Work Agency.
- Geographic risk: Leeds and West Yorkshire have documented historical incidence of labour exploitation in industrial supply chains.
- Operational mitigants: direct founder oversight of every placement, exclusive use of locally-sourced workers, refusal to work with sub-contractors or labour brokers, and long-standing client relationships.
Training
The founder maintains current awareness of Fair Work Agency, Home Office, and Gangmasters and Labour Abuse Authority guidance and updates as they are published.
Effectiveness
The agency monitors the effectiveness of these controls through:
- Direct conversation with workers post-placement.
- Direct conversation with site supervisors at client employers.
- Review of any worker complaints, concerns, or unusual departures.
To date, no instance of modern slavery, human trafficking, or coerced labour has been identified within the agency's supply chain. Any future identified instance will be investigated by the founder personally and reported to the Fair Work Agency where appropriate.
Approval
This statement has been approved by Tony Pugal, founder and director of Tony Pugal Recruitment Ltd, on behalf of the company.
Signed: Tony Pugal — Founder & Director
Date: [Date — populate on Tony approval]
For questions about this statement, contact Tony Pugal directly on 0113 226 1111 or tony@tonypugalrecruitment.co.uk.
