Modern Slavery Policy Statement  

Introduction 

This statement applies to our business operations and supply chain and has been prepared to meet the expectations of Part 6 of the Modern Slavery Act 2015. It informs stakeholders, including our employees, suppliers, third-party partners, and clients, of our stance on modern slavery, human trafficking, forced and bonded labour, and labour rights violations.

Modern slavery is a crime and a violation of fundamental human rights. It includes various forms such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve depriving individuals of their liberty for exploitation and gain.

Although our turnover is below the threshold requiring a formal statement under the Act, we believe that the volume of customer procurement through our supply chain necessitates transparency and action. This statement also aligns with our commitment to sustainable and responsible procurement practices and the UK Government’s Action Plan for implementing the UN Guiding Principles on Business and Human Rights.

To Whom This Policy Applies  

This policy extends to everyone connected with our operations, including employees, contractors, agents, consultants, third-party representatives, and business partners. 

Our Supply Chains

Our supply chains are categorised into the following areas:

·       Labour  

·       Sub- Contractors  

·       Suppliers of equipment and services  

We are committed to ensure that:  

We are committed to ensuring that:

1.     Employment is freely chosen.

2.     Freedom of association and collective bargaining rights are respected.

3.     Working conditions are safe and hygienic.

4.     Child labour is prohibited.

5.     Living wages are paid.

6.     Working hours are reasonable.

7.     No discrimination is practised.

8.     Regular employment is provided.

9.     Harsh or inhumane treatment is not tolerated.

Risk Assessment and Due Diligence

We have processes in place to mitigate the risks of modern slavery and human trafficking in our supply chains. This includes assessing, identifying, addressing, and monitoring risk areas.

For new suppliers, we conduct risk assessments to evaluate the likelihood of any unsatisfactory practices. If concerns are identified:

·       We review their published modern slavery policies (if they are required to comply with the Modern Slavery Act 2015).

·       For other suppliers, we require declarations of compliance and may request additional information about their working practices.

·       Enhanced vetting procedures are applied where higher risks are identified.

Responsibility

Our Board of Directors and HR Management are responsible for ensuring compliance with this policy. Senior management oversees its implementation, monitors its effectiveness, and ensures it addresses risks effectively.

Management teams across the business work to ensure those under their supervision are informed about this policy and trained to identify and address modern slavery risks.

Reporting Concerns

We encourage all stakeholders to raise concerns about any issue or suspicion of modern slavery. Whether it involves our operations, supply chains, or third-party partnerships, we are committed to acting promptly and appropriately.

Concerns raised in good faith will be taken seriously, and we are committed to protecting individuals from detrimental treatment, such as dismissal, disciplinary action, or other unfavourable outcomes.

If concerns are not addressed adequately, we provide further escalation pathways to ensure they are resolved.

Conclusion

We are dedicated to promoting ethical practices throughout our business and supply chains. This policy reinforces our commitment to combat modern slavery, uphold human rights, and support sustainable and responsible procurement practices.

For more information or to report a concern, please contact us at hr@thinkspg.com

Gareth Humphreys

Solution Performance Group

CEO