Dataspire Solutions Limited (“the Company”) has a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships. Modern slavery is a crime and a violation of fundamental human rights. The Company recognises this 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 are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
Responsibility for the Policy
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Managing Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
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. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.
Third Party Compliance with the Policy
Before working with subcontractors for projects, a Director of Dataspire will complete a risk assessment in order to assess the risk of modern slavery. This will include:
- Mapping the supply chain to assess particular product or geographical risks of modern slavery and human trafficking;
- Assess the modern slavery and human trafficking risks of each new supplier
- Policies in place to encourage the reporting of concerns and the protection of whistle blowers
- Engage with our suppliers both to convey to the modern slavery and human trafficking policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses
- Where possible, we build long standing relationships with suppliers and make clear our expectations of business behaviour.
In the event any prospective subcontractor represents an unacceptable risk, Dataspire will consider it our responsibility to work with such companies (as far as is reasonably practical) representatives to assist them in implementing a policy and reducing their risk. This may involve providing training through our training providers and access to our legal advisors.
Communication and Awareness of this Policy
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
Breaches of This Policy
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Adam Norton-Howells – Company Director – Dated – 10/06/2020