This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) and sets out the steps that ITEC Connect LTD (the Company) and its subsidiaries (together, the Group) have taken and will be taking to ensure that slavery and human traﬃcking is not taking place in any part of our business, or that of our supply chain.
The group is committed to running its business responsibly, striving to maintain high ethical principles and having respect for human rights. One of our core values is to behave, and to be recognised, as a good citizen in the communities in which our businesses operate. As part of this value we are aware of our legal and moral obligations towards combatting forced, bonded or compulsory labour, human trafficking and other kinds of slavery and are committed to monitoring and improving our practices in this area on an ongoing basis.
The group does not knowingly conduct business with individuals, Agencies or Companies that conduct, support, condone or facilitate human traﬃcking or slavery.
The Group, which is incorporated, domiciled and trading in the UK, provides Document Management and oﬃce technology to both business’ and consumers. Our key markets are Legal practices and Education.
The Group currently has over 250 employees’ and in the year ending 28th February 2017 reported a revenue of £27,425,000. A list of all subsidiaries as at the same date is noted in our 2017 Annual Report.
We are committed throughout the Group to high standards of corporate governance which we consider are critical to business integrity and to maintaining investors’ trust in us. We expect all our Directors, employees and Suppliers to act with honesty, integrity and fairness. Our business principles set out the standards we set ourselves to ensure we operate lawfully, with integrity and with respect for others. As part of this commitment, we are committed to implementing and enforcing eﬀective systems and controls to ensure slavery and human traﬃcking is not taking place anywhere in our supply chains or in any part of our business. We fully acknowledge our responsibility to respect human rights as set out in the international Bill of Human Rights and we are also committed to implementing the United Nation Guiding Principles on Business and Rights throughout our operations. Any breaches of this Policy will be taken seriously and dealt with on a case by case basis.
The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Personnel Services Manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and eﬀectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are eﬀective in countering modern slavery.
The Group sources a wide range of goods and services from suppliers based both in the UK and overseas. In all of our dealings with those suppliers we strive to ensure that the highest ethical standards are reached at all times. As part of our tendering process, we require our suppliers to support and demonstrate our values, which is an essential component of our approach to Corporate Social Responsibility.
All new employees are subject to pre–employment checks to conﬁrm their identity and eligibility to work in the UK prior to them starting work within the Group. Information is provided to all employees on their statutory rights including sick pay, holiday pay and any other beneﬁts they may be entitled to by virtue of their employment. We pay all directly employed labour at least the living or minimum wage, as relevant. Where recruitment agencies are used, we ensure they comply with all legal requirements. These procedures collectively help to address our on-going commitment to protect our employees’ human rights and the elimination of all forms of forced and compulsory labour.
To ensure a high level of understanding of the risks of modern slavery and human traﬃcking in our supply chains and our business, all Directors have been briefed on the subject and we provide training to relevant members of staﬀ. Through this training, as well as through Group wide internal communications, all employees are encouraged to identify and report any potential or actual wrongdoing that they consider to be negligent, improper or illegal via our Whistleblowing Policy.
We believe that the risk of slavery and human traﬃcking within our own organisation is substantially mitigated as a result of our strong collective sense of vision and purpose, our cultural values and commitment to ethical behaviour, supported by our policies and procedures, however we are not complacent and we recognise that there is always more that can be done. We will continuously seek to develop our practices where possible and to work with our suppliers and contractors to be as certain as we can be that they hold the same values as us.
Wherever possible, we will expect suppliers to have suitable anti-slavery and human traﬃcking policies and processes within their businesses and to cascade those policies to their suppliers. Our standard supplier contractual terms and conditions will be revised to include a provision requiring suppliers (and each of their sub-contractors) to comply with the Act. The standards we expect will address a broad spectrum of working conditions including fair remuneration, working hours, no child labour, respect, non-discrimination, health, safety and wellbeing, as well as freedom from forced labour.
As part of any tender process, we will ask prospective suppliers to conﬁrm compliance with the Modern Slavery Act at the pre-qualifying questionnaire stage. We will not progress to working with any supplier which does not comply with the Act.
We will also commence an audit programme, initially on a risk based approach, within our existing supply chain to verify compliance with the Act and throughout the life cycle of any agreement we reserve the right to conduct audits on our supplier contracts. We will assess any instances of non-compliance on a case-by-case basis, taking any remedial action accordingly.
This Policy will be reviewed regularly (annually) by those responsible for it.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and was approved by ITEC Board of Directors on 12th June 2018.