Introduction

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

The statement sets down Consectus’ commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small.  Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Consectus Ltd which are as follows:

Development of software products and solutions.

The Company currently operates in the following countries:

UK and India.

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

• We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
• The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
• We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
• We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risk-based approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
• Consistent with our risk-based approach we may require:
  • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct
  • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code.

• As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
• If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action.  This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships

High Risk Activities

The following activities are at high risk of modern slavery or human trafficking:

1. Suppliers of basic services in India such as cleaning, food production etc
2. Catering and other service sector suppliers in the UK

Responsibility for the Company’s anti-slavery initiatives is as follows:

• Policies: The Commercial Director is responsible for creating and reviewing policies. The process by which policies are developed is by looking at best practice and adopting as appropriate.
• Risk assessments: The Managing Director is responsible for risk assessments in respect of human rights and modern by a process of including these in the Risk register and ensuring that the correct controls are in place.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to complete an online training course every year.

Our current chosen supplier for this training is Ihasco Ltd.

https://www.ihasco.co.uk/courses/detail/modern-slavery-training

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations

• Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains. See separate
  Whistleblowing Policy
• Code of Conduct – The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
• Corporate Social Responsibility (CSR) Policy – The Company’s CSR policy summarises how we work responsibly with suppliers and local communities.

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all staff to have completed training on modern slavery

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary.

The Board of Directors endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

Name:	Paul D’Ambra
Position:	CEO
Date:	August 2024
Signature:

Download the Statement