Introduction
Nicoll Curtin Group recognises that slavery, servitude, forced labour and human trafficking (together “Modern Slavery”) are issues of global concern. Every company is at risk of being involved in this crime through its own operations and its supply chain. As such, all businesses play a vital role in preventing Modern Slavery.
We have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement.
This statement is made in compliance with the UK Modern Slavery Act 2015 (the “MSA 2015”), which is applicable to all organisations with a group turnover of £36 million or more that are incorporated in the UK or carry on a business in the UK.
Our business and supply chains
Nicoll Curtin is a global expert in Technology and Change recruitment across the world. This statement applies to all subsidiaries of Nicoll Curtin Group Limited.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards, and references.
We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.
Policies and process
Through our policies and transparent culture, we encourage all employees to feel they have a voice to raise any concerns within our organisation and our supply chain.
We regularly review our Whistleblowing. Anti-bribery and code of conduct to ensure we are staying up to date with relevant and local issues.
Risk assessment
We have assessed the risk to Modern Slavery to be very low across our Group, our supply chain and our clients. We have made this assessment on the following factors:
- The industries we recruit for are professional and would be considered “white collar”, as such would not be associated with Modern Slavery.
- We carry out an annual review of our supply chain.
- Any new suppliers are vetted to ensure they reach our minimum standards with regards to compliance and ethics.
Training and awareness
Nicoll Curtin is committed to ensuring that employees understand the risks of modern slavery and human trafficking. Employees are expected to comply with our policies relating to ethical business conduct, whistleblowing, anti-bribery and recruitment practices.
Relevant employees receive training and guidance on identifying potential indicators of modern slavery, reporting concerns and understanding their responsibilities in helping to prevent modern slavery within our business and supply chain.
We will continue to review our training requirements annually to ensure they remain appropriate to the nature and size of our business.
Measuring effectiveness
To assess the effectiveness of our actions to combat modern slavery, we monitor the following key performance indicators:
- 100% of new suppliers are subject to appropriate onboarding and due diligence checks.
- 100% of reported concerns relating to modern slavery, forced labour or unethical working practices are investigated.
- Annual review of relevant policies, including Whistleblowing, Anti-Bribery and Code of Conduct policies.
- Annual review of this Modern Slavery Statement by senior management and the Board.
- Monitoring of any modern slavery-related incidents identified within our operations or supply chain.
During the financial year ended 31 December 2025, no instances of modern slavery or human trafficking were identified within Nicoll Curtin's operations or reported through our whistleblowing procedures.
Actions taken
During this financial year we intend to continue combatting Modern Slavery and will ensure:
- No one will be charged any fees to obtain work from us, indulging via our clients
- All global policies are reviewed at least once in a financial year
- Our employment contracts and all contracts with our candidates comply with local laws
- We maintain a clear process for carrying out background checks where absolutely required
- We review this statement and steps taken on an annual basis
- We maintain clear whistleblowing and reporting procedures.
- We support freedom of association and equal opportunities for all workers.
- We provide fair wages and working hours in accordance with applicable legislation.
- We prohibit child labour, forced labour, human trafficking and all forms of modern slavery throughout our business and supply chain.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and relates to the financial year ended 31 December 2025. Approved by the Board of Directors and signed on its behalf by Madeleine Richards, Group Head of Governance and Company Secretary, on July 2026.