MODERN SLAVERY STATEMENT 2020/21
Modern slavery is a heinous crime and Novatech operates a zero tolerance commitment to slavery and human trafficking. Under the Modern Slavery Act 2015 (the Act), we are dedicated to ensuring that human trafficking, slavery, forced or compulsory labour and/or servitude does not take place at any point in our business or in our supply chains.
Our structure and supply chains
Novatech operates from Hampshire and has 100 employees. We are predominantly UK-focussed, with approximately two thirds of our business coming from the SME, education and defence sectors and the remainder of our sales coming from retail.
Operating in the IT sector, we source IT hardware and peripherals internationally, from global manufacturers. We custom-build, design, install and manages IT infrastructures to UK B2B and B2C markets. In doing so, we work with over 350 suppliers who are largely based in the UK (over 95%), with the remainder of its supply chain from Europe, USA and the Far East. We therefore consider that there is a relatively low risk of modern slavery and/or human trafficking occurring within our supply chain, however we strive to ensure that we have the right procedures and practises in place to be able to operate ethically.
Due diligence
We recognise that due diligence processes and reporting are essential management tools to improve risk identification.
Suppliers
We undertake stringent due diligence processes to ensure we only use suppliers who share our commitment to ethical practices. By working to secure a transparent supply chain through operating due diligence, we seek to prevent modern slavery from occurring in the course of our operations by:
• Fully committing to our Supplier Code of Conduct. We expect all suppliers to meet the provisions set out within this.
• Having a clear Supplier Application processes in place for supplier approval.
• Obtaining Modern Slavery statements from suppliers, where available.
• Vet suppliers so far as is possible of their own compliance with the requirements of the legislation.
• Routinely analyse our supply chain, a task which is carried out at senior level, by the Purchasing Manager and Finance Director.
• Removing suppliers from our Approved Suppliers List after 12 months of inactivity. Suppliers will have to complete the registration process again to re-join.
Employees
We conduct all business in an ethical manner and are committed to being a transparent organisation and employer. We do not consider there to be a high risk of slavery or human trafficking within our workforce, however we have the following in place:
• A robust recruitment process, incorporating ‘right to work' document checks, contracts of employment and ensuring everyone employed is 16 years or above.
• A comprehensive Employee Handbook which has a range of procedures to support in preventing modern slavery from occurring in our workplace.
• Training on the Modern Slavery Act and human trafficking.
• A whistleblowing policy and procedure to honour our responsibility to protect whistleblowers when highlighting any risk of slavery or human trafficking at Novatech.
• Company Values that set the parameters for how we expect people to interact with colleagues, partners and customers.
Everyone at Novatech is required to comply with legal requirements at all times.
Future Performance Indicators
We understand and strongly feel that combating modern slavery and human trafficking is vitally important. In our business year 2020/21, we will continue to support this by:
• Ensuring all our employees who are involved with our suppliers continue to undertake training (including any refresher training) on Anti-slavery and trafficking training. This ensures our people remain vigilant and have up to date knowledge.
• Ensure we have the latest modern slavery statements and other relevant policies of key suppliers, reviewing these as part of our standard assessment of supply chain risks.
• Review our Supplier Code of Conduct
• Update our whistleblowing policy to include a reference that any concerns of modern slavery and trafficking may be reported through this whistleblowing procedure.
Novatech takes responsibility for this Statement and its related objectives, and review and update it in accordance with the Act.