Modern Slavery & Human Trafficking Statement

​For financial year 2018/19

Purpose

The Modern Slavery Act 2015 came in to force on the 29th of October 2015, with the aim of reducing and preventing modern slavery and human trafficking. All commercial organisations operating in the UK, with a turnover of £36 million or greater are required to publish, or make available, a Modern Slavery and Human Trafficking Statement. Every organisation’s Modern Slavery and Human Trafficking Statement must be reviewed, updated, and re-published each financial year.

This statement sets out GBM Digital Technologies LTD’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

Scope

This statement relates to actions and activities during the financial year (1 January 2018 to 31 December 2018). As part of it’s operations to provide ICT hardware and services to consumers, businesses, educational establishments, charities, and public sector bodies, GBM Digital Technologies LTD recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

GBM Digital Technologies LTD is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational Structure

GBM Digital Technologies LTD is a wholly owned subsidiary of GBM Digital Technology Holdings LTD. GBM Digital Technologies LTD [GBM] are an ICT hardware and services provider, providing technology-oriented products and services to consumers, businesses, educational establishments, charities, and public sector bodies.

GBM operate in the UK only, and supply within the UK and EU only.

Supply Chains

Our supply chain consists of product manufacturers, product distributors, and service providers. GBM source all good and services from companies with a presence in the UK and/or EU.

Our supply chains are non-complex, and typically fall in to one of two models:

  • Purchasing directly from the manufacturer
  • Purchasing from a distributor, who is authorised to distribute goods and services on behalf of the manufacturer

Responsibility

The responsibility for GBM’s anti-slavery initiatives is as follows:

Policies - Board of Directors

Risk Assessments - Procurement regarding supply, HR regarding employment

Investigations & Due Diligence - Board of Directors

Training - Board of Directors

Relevant policies

GBM operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy

GBM encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of GBM. This includes any circumstances that may give rise to an enhanced risk of slavery or human tra cking. GBM’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

  • Employee code of conduct

The GBM’s code makes clear to employees the actions and behaviour expected of them when representing the GBM. GBM strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

  • Supplier Code of Conduct

In 2018, GBM will introducing a Supplier code of conduct. The code of conduct will outline GBM’s commitment to ensuring that it’s suppliers adhere to the highest standards of ethics. Suppliers will be required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. GBM will work with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the Supplier Code of Conduct will lead to sanctions against the supplier, and ultimately termination of the business relationship. The target date for completion of this activity is September 2018.

Recruitment Policy

In 2018, GBM will be introducing a more robust Recruitment policy, which will include:

  • conducting ‘eligibility to work in the UK’ checks for all employees to safeguard against human trafficking or individuals being forced to work against their will
  • procedures to ensure that GBM only utilises reputable employment agencies to source labour, and always verifies the practices of any new agency it is using before accepting workers from

The target date for completion of this activity is May 2018.

Due Diligence

In 2018, GBM will be introducing processes to undertake enhanced levels of due diligence when considering taking on new suppliers, and regularly review its existing suppliers. GBM’s due diligence and reviews will include:


  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship
Assessing Risk

In 2018, GBM are introducing new measures to assess and manage the risk of activity carried out across our supply chain. This will form part of our supply chain vetting process, and will take key risk areas in to account, including those associated with:
  • Country
  • Sector
  • Transactions
  • Business partnerships

Performance indicators

GBM has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the GBM is:

  • developing a system for supply chain verification, expected to be in place by September 2018, whereby the GBM evaluates potential suppliers before they enter the supply chain; and
  • reviewing its existing supply chains, expected to be completed by September 2018, whereby the GBM evaluates all existing suppliers.

We will monitor the e ectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain. The key metric being that no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

Training

Our policies, (i.e. Whistleblowing, and Employee Code of Conduct) are currently made available to all employees via the staff handbook. During 2018, GBM will expand on this, make training available to all of it’s employees, with an aim to both:

  • raise awareness, and educate our employees about Modern Slavery and Human Tra cking, and
  • inform them about our internal policies for prevention.

The target date for completion of this activity is August 2018.

Board Approval

This statement has been approved by the GBM’s board of directors, who will review and update it annually. 5th January 2018.