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Anti-Slavery & Human Trafficking Statement

This statement sets out the steps that continue to be taken by Celerity Limited to seek mitigating the risk of Modern Slavery or Human Trafficking occurring within our Company and our Supply Chain and in doing so, conform to the requirements of the Modern Slavery Act 2015.

Modern Slavery is a broad term covering instances where victims may be subject to conditions of slavery, servitude and forced or compulsory labour. We continue to review our policies and processes in this area, with a view to improving our understanding of the risks within our Supply Chain and the mitigation we need to put in place.

We continue to monitor and develop our procurement processes. Our focus is to enhance our supplier due diligence processes, to aid compliance with our commitment to prevent Slavery or Human Trafficking being present in any part of our business. Our aspirations in addressing Modern Slavery go beyond legal compliance considerations. In line with our corporate purpose and principles, it is simply the right thing to do.

1. Our Organisation and Supply Chain

Our business comprises two key focus areas: the design and deployment of often complex IT solutions, and the provision of a range of IT services. The Celerity client base covers the public sector, NHS and vertical markets such as finance, defence, manufacturing and energy.

To support these activities, we have a range of Suppliers on our Vendor database. The majority of these Suppliers are UK based, however some of these have supply chains extending into countries that may be considered a risk in terms of Modern Slavery. Our current and developing due diligence measures are outlined below, in section 3.

2. Policies in Place

Modern Slavery Policy - We have a zero-tolerance approach to Modern Slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place in our own business or in any part of our Supply Chain. If we were to become aware that any of our Suppliers was in any way accepting of Modern Slavery, we would look to work with that supplier to address the issue. We would review our rights to terminate the relevant contract(s) only as a last resort. Our primary aim would be to try and address the root cause of an issue.

Ethics in our Business Policy – We understand the importance of operating with honesty and integrity in our business. We have captured this in a single ethics statement which applies to everyone who works for or on behalf of the business. We are providing a supportive environment for colleagues to voice any concerns. Specific highlights of the policy include:

  • Complying with relevant laws
  • Following procedures and policies
  • Zero tolerance for bribery and corruption

This policy will be subject to annual Board review to ensure it remains fit for purpose. Training is being provided to everyone in the organisation, with refresher sessions being run periodically.

Employment Screening Policy – It is important that we also minimise the risk of Modern Slavery among the colleagues we employ directly. Although perceived as extremely low risk, we carry out pre-employment checks during recruitment.

3. Due Diligence Measures in Place

Our due diligence procedures to assess our Supply Chain are proportionate to the risk of Modern Slavery. These procedures can be summarised as follows:

  • Issuing our Modern Slavery policy and our Business Ethics policy to those organisations that we contract to make our stance on these matters clear
  • Reviewing our Suppliers in terms of the level of business we do with them, whether they are based in ‘high’ risk areas of the world, where slavery might be more prevalent and the product types they supply us with, see section 4, ‘Risk Assessment’ below
  • Building in enhanced coverage of the Modern Slavery Act within our procurement processes
  • Making clear our position on Modern Slavery and expectations from our Suppliers in writing to our supplier base
  • Discussing the matter with our key Suppliers during regular review meetings, to raise the visibility and awareness of Modern Slavery risks
  • Asking key Suppliers to demonstrate to us the measures they have in place to prevent Modern Slavery arising in their own supply chains
  • Our standard contractual terms require Suppliers to comply strictly with the Modern Slavery Act and the UN Convention on the Rights of the Child

4. Risk Assessment

Our Supply Chain is risk assessed using the following criteria to assess and manage risks to workers:

  • Country Risks: Exposure may be greater in global supply chains in countries where protection against breaches of human rights is more limited than in the UK. We have a range of Suppliers, some of whom may procure materials or components from such countries. We are working with Suppliers to gain a more detailed understanding of the impact on our Supply Chain.
  • Business Partnership Risk: Our key contractual Partners tend to be longer term and therefore involve less risk as we build up a good knowledge of our Partner’s operation and policies.

5. Training and Awareness

The company undertakes measures to help raise awareness of Modern Slavery amongst our colleagues and Suppliers and embed policy requirements which can be summarised as:

  • Issuing our Modern Slavery policy and our Business Ethics policy to our employees
  • Targeted sessions with those areas of the Company, more likely to come in to contact with activities
    associated with slavery
  • Educating all our employees via periodic articles in our Company bulletins and newsletters
  • Holding briefing sessions with our key Suppliers to raise the visibility and awareness of Modern Slavery risks, and the need for mitigation to be put in place
Progress in achieving these measures is monitored on a regular basis.

6. Continuous Improvement

Celerity understands that we have a responsibility to continue to assess and mitigate the risk of Modern Slavery. We will continue to remain vigilant and review our approach to ensure that we have appropriate mitigation in place for this risk. We will not tolerate Modern Slavery in any form within our business, including our wider Supply Chain.