Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain. Our employees are alert to the risks and are expected to report their concerns, and management are expected to act upon them.
Define Tech Limited, trading as Define Tech, is an independent software vendor
(ISV). The head office is based in London and we support a remote workforce that spans the UK and Ireland.
The principal activity of our business is the wholesale of IT software solutions and complimentary IT hardware.
OUR SUPPLY CHAINS
Our supply chains include the sourcing of hardware products from UK and USA based suppliers.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.
DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING
As part of our initiative to identify and mitigate risk we:
- Build long-standing relationships with our suppliers and make clear our expectations of business behaviour.
- Have a policy of “knowing our customer” to ensure that we are contracting with appropriate businesses.
- With regards to national or international supply chains, we expect these entities to have suitable anti-slavery and human trafficking policies and processes. We expect each entity in the supply chain to, at least, adopt ‘one-up’ due diligence on the next link in the chain. It is not practical for us (and every other participant in the chain) to have a direct relationship with all links in the supply chain.
We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.
SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain and contractors to comply with our values.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide briefings to our Directors and employees.
OUR EFFECTIVENESS IN COMBATING SLAVERY AND HUMAN TRAFFICKING
We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chain:
- Auditing of internal control systems.
- Level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.
- Training and induction for all new employees.
BREACHES OF THIS POLICY
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year.