Modern Slavery Policy
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and bonded labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
With c.36 million modern slavery victims worldwide, c.8300 cases of modern slavery in the UK in 2019, and reports that this is on the increase, the Company recognises the need to raise awareness and take proactive action to prevent or combat modern slavery should it enter our business or any company with which we do business.
We therefore adopt a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any company with which we do business.
The Company is engaged in the supply of software and associated services to its customers.
Pursuant to Section 54 of the UK Modern Slavery Act of 2015, the Company provides the following statement:
The Company has built its foundations with strong values and is committed to these values:
- We recognize that everyone is unique and we act in a way to ensure that our customers gain an exceptional experience
- We treat everybody with respect, loyalty and fairness and cultivate success based on long term relationships
- We act with honesty, transparency and with the best interests of all of our customers with everything we do
- We practice ethical behaviour with integrity and we encourage others to follow these values by leading by example and we act to protect others from harm.
These values are directly relevant to the issues associated with eradicating the evil of modern slavery and the Company is committed to developing and improving its processes to combat slavery and human trafficking.
The Company respects human rights and workplace rights. The Company is committed to conducting its business in a manner that protects these rights and prohibits and opposes all forms of modern slavery, servitude, forced and bonded labour and human trafficking.
The Company uses the following key performance indicators to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:
- Use of labour monitoring, right to work documentation and payroll audits
- We maintain a strong level of communication and personal contact with the next link in the supply chain to ensure their understanding of, and compliance with, our expectations
- We are committed to reviewing our policies, procedures and working practices in line with developments in the understanding of, and approach to, modern slavery and human trafficking issues.
An overview of the Modern Slavery Act 2015 (UK) and other supporting documents can be viewed https://www.gov.uk/government/collections/modern-slavery-bill.
Policies and Practices
Company Policies and Procedures
The Company sets forth our core principles and values and expectations regarding responsible and ethical business conduct in our Policies and Procedures. As such, our Policies and Procedures detail the standards of integrity that the Company requires all of its directors and employees to follow. Our Policies and Procedures constitute our commitment to act ethically and with integrity in all of our business relationships, including respecting human rights and workplace rights, opposing modern slavery and human trafficking of any kind, as well as providing guidance on how to report any violations of our Policies and Procedures. The Company endeavours to maintain business relationships with business partners that are similarly committed to the principles, values and expectations outlined in our Policies and Procedures.
Third Party Suppliers
The Company endeavours to maintain business relationships with third-party suppliers that are committed to respecting human rights and workplace rights. Consistent with our ongoing review of our business practices, the Company will further refine its Policies and Procedures in the manner that it deems to be most appropriate and effective.
The Company respects and values its employees. To ensure that our employees are not subject to undue influence and are treated fairly and with respect, the Company has human resources policies and procedures, as well as recruitment processes, in place across all of its operations.
As indicated above, our Policies and Procedures specifically assert our respect for human rights and opposition to human trafficking. The Company requires all of our directors and employees to comply with our Policies and Procedures. At new hire orientation and training and periodically thereafter, all employees receive a copy of and are required to attest to receiving and understanding our Policies and Procedures.
The Company maintains an open door policy for employees to raise concerns without fear of retaliation. Employees can confidentially report any concerns, which may include concerns relating to modern slavery and human trafficking. These reports are then investigated in accordance with our Policies and Procedures.
Our Policies and Procedures govern and guide the business conduct of the Company and its employees. As we hold ourselves to these high ethical principles and values, we endeavour to ensure that the business conduct of our third party suppliers complies with all relevant laws and that said suppliers embrace our ethical principles and values.
Violations of our Policies and Procedures by our employees may subject them to disciplinary action, including dismissal (unless prohibited by law). We also reserve the right, pursuant to contractual provisions or otherwise to the extent permitted by law, to terminate relationships with third parties who violate our Policies and Procedures or who otherwise engage in unlawful activities.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year.