Vacancies

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT

Last Updated: 2 September 2026

1. ORGANISATION

We, Placing People Direct LLC (“we,” “us,” or “our”), are committed to preventing modern slavery, human trafficking, forced labour and exploitation within our organisation, recruitment activities, business relationships and supply chains.

Placing People Direct LLC is an independent recruitment and employment services organisation specialising in the education, early years, childcare, schools, further education and related sectors.

We operate in the United Arab Emirates and are committed to conducting our activities ethically, responsibly and in accordance with applicable UAE laws and regulations.

2. DEFINITIONS

We consider modern slavery and exploitation to include, but not be limited to:

  • Human trafficking;
  • Forced or compulsory labour;
  • Forced work through threats, coercion, intimidation or abuse;
  • Debt bondage or other forms of exploitation;
  • The use of deception or fraud to obtain or retain a person’s labour or services;
  • Abuse of vulnerability or position of authority for the purpose of exploitation;
  • Unlawful restriction of an individual’s freedom of movement;
  • Withholding or controlling personal documents or other means of identification for the purpose of exploitation; and
  • Any other practice that constitutes forced labour, human trafficking or exploitation under applicable UAE law.\

3. COMMITMENT

We have a zero-tolerance approach to modern slavery, human trafficking, forced labour and exploitation.

We are committed to conducting our business ethically, responsibly and with respect for the dignity, safety and human rights of all individuals who interact with our organisation.

In relation to our UAE activities, we are committed to complying with all applicable UAE legislation concerning employment, labour rights and the prevention of human trafficking and exploitation, including:

  • Federal Decree-Law No. 24 of 2023 on Combating Human Trafficking; and
  • Federal Decree-Law No. 33 of 2021 on the Regulation of Labour Relations, as amended, together with applicable implementing regulations and resolutions.

We will not knowingly enter into or maintain a business relationship with any organisation that is found to be involved in human trafficking, forced labour, modern slavery or other serious forms of labour exploitation.

We will take reasonable and proportionate steps to identify, assess and mitigate modern slavery and human trafficking risks within our operations, recruitment activities and supply chains.

4. ORGANISATIONAL STRUCTURE

Placing People Direct LLC is an independent recruitment and employment services organisation specialising in the education, early years, childcare, schools, further education and related sectors.

Trade Licence No.: 2539913.01

Our activities include supporting employers and candidates with recruitment and employment opportunities.

Our UAE activities may include supporting employers and candidates in sectors including education, early years, childcare and related professional services.

Where recruitment and employment activities take place in the UAE, we will ensure that they are conducted in accordance with applicable UAE laws and regulatory requirements.

5. SUPPLY CHAIN STRUCTURE

Our principal supply chains relate to recruitment, candidate sourcing, employment support, placement and related professional services.

These may include:

  • Candidates seeking employment opportunities;
  • Schools, nurseries, colleges and educational organisations;
  • Employers and other organisations seeking staff;
  • UAE-based recruitment and employment service providers;
  • Training and professional development providers;
  • Compliance and background-check providers;
  • Payroll and administrative service providers;
  • Technology and software providers;
  • Immigration, visa and employment-related service providers where applicable; and
  • Other professional service providers supporting the delivery of our recruitment activities.

We recognise that some first-tier suppliers may themselves use subcontractors or lower-tier suppliers. Where appropriate, we will seek reasonable assurance that such organisations operate ethically and comply with applicable UAE legislation and recognised standards concerning labour rights and human trafficking.

We recognise that recruitment businesses can face particular risks because candidates may be vulnerable to exploitation, particularly where they are relocating internationally, are unfamiliar with local employment laws, experience language barriers, or depend upon third parties for employment, accommodation, transport or immigration arrangements.

We therefore take these factors into account when assessing our recruitment and supply chain risks.

6. ORGANISATIONAL POLICIES

We have implemented policies and procedures designed to support ethical recruitment, safeguarding, responsible business practices and the prevention of exploitation.

Our relevant policies include:

  • Modern Slavery and Human Trafficking Policy – setting out our zero-tolerance approach to modern slavery, forced labour, human trafficking and exploitation;
  • Safer Recruitment Policy – outlining procedures for recruiting, screening and placing candidates;
  • Safeguarding and Child Protection Policy – reflecting the nature of our work within education and childcare;
  • Equality, Diversity and Inclusion Policy – promoting dignity, respect and equality of opportunity;
  • Whistleblowing Policy – providing mechanisms for employees, candidates, clients and stakeholders to raise concerns;
  • Anti-Bribery and Corruption Policy – promoting honest and ethical business practices;
  • Data Protection and Confidentiality Policy – governing the appropriate handling of personal information; and
  • Supplier and Partner Code of Conduct – establishing ethical expectations for suppliers, contractors and business partners.

Copies of relevant policies are available upon request.

We regularly review our policies and procedures to ensure that they remain effective, proportionate and aligned with applicable legislation and recognised good practice.

7. ASSESSING AND MANAGING RISK

We recognise that recruitment businesses may be exposed to modern slavery and human trafficking risks through both their own activities and wider supply chains.

In relation to our UAE activities, particular areas of potential risk may include:

Candidate Recruitment and Placement

Candidates may be vulnerable to exploitation because of:

  • Language barriers;
  • Limited understanding of UAE employment rights;
  • Financial circumstances;
  • Immigration or visa dependency;
  • Reliance on third parties for accommodation or transport;
  • Lack of familiarity with the employer or recruitment process; or
  • Dependence upon intermediaries or other third parties.

Recruitment Fees

We recognise the importance of ensuring that candidates are not subjected to unlawful recruitment charges or other financial arrangements that could contribute to debt bondage or exploitation.

Where UAE recruitment activities are undertaken, we will ensure that recruitment arrangements comply with applicable UAE law.

We will not knowingly participate in arrangements where candidates are unlawfully charged recruitment or employment fees.

International Recruitment

Where candidates are recruited internationally for UAE employment, we will seek to ensure that candidates receive clear information regarding:

  • The employer and role;
  • Employment terms and conditions;
  • Salary and benefits;
  • Recruitment arrangements;
  • Visa and work permit arrangements;
  • Any relevant costs and responsibilities; and
  • How concerns can be raised.

We will not knowingly participate in arrangements involving deception, coercion, forced labour or exploitation.

Suppliers and Business Partners

We will seek to work with reputable employers, suppliers, contractors and professional partners that demonstrate appropriate ethical standards.

Where appropriate, due diligence may include reviewing:

  • Company registration and licensing;
  • Recruitment or employment-related licences where applicable;
  • Policies concerning labour rights and human trafficking;
  • Reputation and compliance history;
  • Contractual commitments;
  • Recruitment practices; and
  • Procedures for raising and responding to concerns.

Third-Party Recruitment

Where third parties are involved in sourcing or referring candidates, we will seek to ensure that appropriate controls are in place to prevent exploitative recruitment practices.

We will not knowingly work with intermediaries that charge candidates unlawful recruitment fees, use deception, retain identity documents improperly, or engage in coercive or exploitative practices.

8. DUE DILIGENCE

We carry out reasonable and proportionate due diligence to identify and mitigate the risks of modern slavery and human trafficking.

Our due diligence measures include:

Supplier Due Diligence

We seek to engage reputable organisations that share our commitment to ethical recruitment and responsible employment practices.

Where appropriate, suppliers and partners may be asked to confirm that they comply with applicable laws and have appropriate policies and procedures relating to modern slavery, human trafficking and labour exploitation.

Employer Due Diligence

Before working with employers, we seek to establish that the organisation is legitimate and that the employment opportunity being offered is genuine.

Where appropriate, this may include verification of company details, employment requirements and relevant regulatory or licensing information.

Safer Recruitment

We use appropriate recruitment and candidate verification procedures, including identity verification, qualification checks, employment history checks and other checks appropriate to the role and jurisdiction.

For UAE-based employment, relevant work permit, employment and immigration requirements will be considered and appropriate checks undertaken.

Recruitment Fee Protection

We will not knowingly participate in recruitment arrangements where candidates are unlawfully charged recruitment or employment fees.

We will encourage candidates to understand their employment terms and to raise concerns if they are asked to make inappropriate or unlawful payments.

Candidate Protection

Candidates will be encouraged to understand the terms of the opportunities being presented to them.

Where appropriate, candidates will be provided with information regarding their employment arrangements and encouraged to report any concerns about coercion, exploitation, threats, deception or other inappropriate conduct.

Whistleblowing and Reporting

Employees, candidates, clients, suppliers and other stakeholders are encouraged to report concerns relating to modern slavery, human trafficking, forced labour or exploitation.

All concerns will be treated seriously and investigated appropriately.

Ongoing Monitoring

We will periodically review our recruitment practices, supplier relationships and business arrangements to identify emerging risks and determine whether additional controls are required.

9. TRAINING AND AWARENESS

We recognise that employee awareness is an important part of preventing modern slavery and human trafficking.

We will promote awareness of:

  • The risks and indicators of modern slavery and human trafficking;
  • Forced labour and exploitation;
  • Ethical recruitment practices;
  • Candidate vulnerability;
  • UAE employment and labour protections relevant to our activities;
  • Recruitment fee risks;
  • Safeguarding responsibilities;
  • Whistleblowing and reporting procedures; and
  • The importance of treating all candidates and employees with dignity and respect.

Employees and associates involved in recruitment will be encouraged to remain alert to indicators of exploitation and to escalate concerns appropriately.

Training and awareness arrangements will be reviewed periodically to reflect changes in legislation, business activities and identified risks.

10. MONITORING AND EVALUATION

We will monitor the effectiveness of our measures through appropriate performance indicators, including:

  • Zero tolerance of substantiated modern slavery, forced labour or human trafficking within our direct operations;
  • Ensuring relevant employees and associates are aware of our Modern Slavery and Human Trafficking Policy;
  • Monitoring completion of relevant recruitment, safeguarding and compliance training;
  • Regular review of key suppliers, employers and business partners;
  • Investigation and appropriate action in response to concerns raised;
  • Monitoring recruitment practices and candidate experiences;
  • Monitoring compliance with relevant UAE employment requirements;
  • Maintaining appropriate records of concerns, investigations and actions taken; and
  • Annual review of this statement and associated policies.

The management team will review the effectiveness of these measures and implement improvements where appropriate.

11. STEPS TAKEN TO PREVENT MODERN SLAVERY

We have not, to our knowledge, knowingly conducted business with an organisation involved in modern slavery or human trafficking.

We have taken, or intend to take, the following steps in relation to our UAE activities:

  • Maintaining a zero-tolerance approach to modern slavery, forced labour, human trafficking and exploitation;
  • Applying appropriate due diligence to employers, suppliers and business partners;
  • Ensuring recruitment activities are conducted ethically and transparently;
  • Taking reasonable steps to prevent candidates being subjected to unlawful recruitment fees;
  • Verifying candidate identities and relevant employment documentation;
  • Seeking to ensure that employment opportunities are genuine and accurately represented;
  • Providing candidates with clear information about employment opportunities;
  • Maintaining appropriate reporting and whistleblowing mechanisms;
  • Providing relevant staff with modern slavery and exploitation awareness;
  • Reviewing recruitment and supply chain risks periodically;
  • Including appropriate ethical and labour standards within supplier and partner arrangements; and
  • Reviewing this statement and related policies annually.

Through these measures, we demonstrate our continued commitment to preventing modern slavery and ensuring that ethical standards are embedded across all aspects of our operations and partnerships.

12. GOVERNANCE AND REVIEW

This statement is approved on behalf of Placing People Direct LLC.

We will review this statement at least annually and may review it sooner where there are significant changes to our operations, supply chains, applicable legislation, regulatory requirements or identified risks.

We recognise that preventing modern slavery and human trafficking requires ongoing vigilance, responsible recruitment practices, appropriate due diligence and continuous improvement.

We are committed to ensuring that all individuals connected with our business are treated fairly, ethically and with dignity and respect.

Trade Licence No.: 2539913.01

Date of approval: 2 September 2026

Next review: September 2027

13. CONTACT US

If you have questions, requests, concerns or information relating to modern slavery, human trafficking, forced labour, exploitation or our approach to preventing these practices, please contact us:

Email: info@placingpeopledirect.ae

Phone: +971 56 880 0667

Placing People Direct LLC
Trade Licence No.: 2539913.01