7.28 Modern Slavery & Human Trafficking Policy

 

7.28.1 Purpose 

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This statement sets out ICS.AI’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.

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The Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking and 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.

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7.28.2 Company and Supply Chain Information

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ICS.AI Ltd are a Microsoft Partner with expertise delivering both on-premise and cloud based services and solutions across the Microsoft technology stack. The organisation currently only operates within the UK. ICS.AI Ltd avoids contracting with suppliers or sub-contractors which are located within geographical areas where slavery and human trafficking are a higher risk. We expect our suppliers to pass on this obligation to their supply chain in higher risk countries

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7.28.3 Responsibilities

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Overall responsibility for the Company’s anti-slavery initiatives lie with the Board of Directors who will ensure that appropriate risk assessments, due diligence and training activities are undertaken to ensure that modern slavery is not taking place in the Company or within its supply chains.

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7.28.4 Associated Policies and Processes

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The Company operates the following policies / documents to support its approach to the identification of modern slavery risks the prevention of slavery and human trafficking in its operations:

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• Public Interest Disclosures: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s Public Interest Disclosure procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. 

• Employee Handbook: The Company’s employee handbook makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.

• Recruitment: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. 

• Supplier Code of Conduct The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are 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. The Company works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the Company’s supplier code of conduct will lead to the termination of the business relationship.

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7.28.5 Performance indicators

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The Company has reviewed its key performance indicators (KPIs). As a result, the Company:

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• Requires appropriate staff to have completed training on modern slavery;

• Will develop a system for supply chain verification, whereby the Company evaluates potential suppliers before they enter the supply chain; and

• Will review its existing supply chains, whereby the Company evaluates all existing suppliers.

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7.28.6 Training

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The Company’s modern slavery training covers:

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• Our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;

• How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

• How to identify the signs of slavery and human trafficking;

• What steps should be taken if slavery or human trafficking is suspected;

• What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative;

• What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and what steps the Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company’s supply chains. 

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