Modern Slavery Act
1. Introduction
We are committed to identifying and mitigating modern slavery risks within our business and supply chain. This Modern Slavery Policy outlines our dedication to addressing these issues and complying with relevant laws. As an ethical employer, Storetec acknowledges its responsibility to address slavery, human trafficking, and exploitation. We also recognise our duty to report suspected victims of slavery or human trafficking, as mandated by section 52 of the Modern Slavery Act 2015.
2. Our Organisation
Storetec Services Limited, established in Hull, UK, provides comprehensive document management solutions, specializing in document scanning, cloud storage, data capture, and digital transformation services. Our diverse client base includes FTSE 100 companies and public sector organizations. We operate a compact supply chain, procuring approximately £800,000 in goods and services annually from various contractors and suppliers. Our supply chain includes technology providers, office supplies, and general maintenance services, primarily located in the UK and Europe.
The company’s leadership consists of a Board of Directors and Senior Management Team who oversee different operational aspects. The Board is responsible for overarching governance, including the commitment to ethical standards and compliance with modern slavery legislation. The Senior Management Team oversees the implementation and maintenance of these policies across all departments.
All of Storetec’s employees, contractors and suppliers are responsible for understanding and adhering to this policy, as well as all other relevant laws, regulations, and policies, including Storetec’s Supplier Code of Conduct.
3. What is Modern Slavery?
Modern Slavery is a term used to describe various forms of exploitation and coercion in which individuals are deprived of their freedom and forced to work under exploitative conditions. It includes practices such as slavery, forced labour, human trafficking, debt bondage, and child labour.
Under the Modern Slavery Act 2015, which applies to organisations operating in the United Kingdom, modern slavery is defined as:
Slavery: The condition of a person being owned or controlled by another person, treated as property, and forced to work or provide services against their will.
Forced Labour: Any work or services performed by an individual under coercion or threat, where they have not voluntarily offered themselves for the work.Human Trafficking: The recruitment, transportation, transfer, or receipt of individuals by means of threat, force, deception, or other forms of coercion for the purpose of exploitation. This includes both domestic and international trafficking.
Debt Bondage: The use of debt or a loan as a form of coercion to force individuals to work in exploitative conditions.
Child Labour: The engagement of children in work that is mentally, physically, socially, or morally harmful, and interferes with their education and development.
4. Our Policies
Storetec is committed to preventing slavery, human trafficking or exploitation in all of its business activities and to ensuring that its supply chains are free from slavery and human trafficking. We will do this by:
4.1. Risk Assessments
a.) We will conduct a thorough risk assessment of our operations and supply chain to identify areas that may be at risk of modern slavery.
b.) The risk assessment will consider factors such as geographic location, industry, and nature of the supplier’s operations.
c.) The risk assessment is reviewed biannually by the Board of Directors and the Compliance Team. Through our risk treatment program, each risk is evaluated based on likelihood and consequence, with high risks automatically flagged for treatment. Specific actions are then defined to mitigate these risks, ensuring effective risk management.
4.2. Supplier Due Diligence
a.) We will implement robust due diligence processes to assess and monitor our suppliers’ compliance with modern slavery laws, such as by issuing self-assessment questionnaires, validating certifications, and conducting on-site audits of our primary suppliers.
b.) New suppliers will be evaluated based on their commitment to combating modern slavery, including their policies and practices, and evidence will be requested wherever required.
c.) Existing suppliers will be periodically assessed to ensure ongoing compliance.
d.) Where suppliers are found to be non-compliant, we will work with them to address the issues and support their improvement. However, if a supplier fails to demonstrate a commitment to eradicating modern slavery, appropriate actions, including termination of the business relationship, may be taken.
4.3. Recruitment
a.) Storetec’s recruitment processes are transparent and reviewed regularly by the Senior Management Team. This includes robust procedures in place for the vetting of new employees and ensures they are able to confirm their identities and qualifications, and they are paid directly into an appropriate, personal bank account.
b.) Storetec expects all employees to demonstrate the highest standards of conduct and behaviour. All breaches are investigated by the Senior Management Team. Storetec recognises its responsibility to develop, implement and monitor policies and procedures within its supply chain to safeguard against the exploitation of underage workers and vulnerable adults.
4.4. Employee Awareness and Training
a.) We will provide training to our employees to raise awareness about modern slavery and the importance of identifying and reporting any suspected cases. This training will include information on the signs of modern slavery, reporting mechanisms, and the impact of modern slavery on individuals and communities.
b.) Training programs will be tailored to the specific roles and responsibilities of employees. For instance, procurement staff will receive detailed training on identifying red flags in supply chains, while HR personnel will focus on recognising and addressing exploitation in recruitment and employment practices.
c.) Employees are encouraged and trained to report any concerns or suspicions related to modern slavery through appropriate channels. These mechanisms ensure that employees can report safely and confidently, knowing their concerns will be taken seriously and addressed promptly.
4.5. Reporting and Whistleblowing
a.) Storetec encourages all its employees, customers and other business partners to report any concerns related to the direct activities or the supply chain of Storetec.
b.) Storetec’s Code of Conduct covers the whistleblowing procedure and it is designed to make it easy for employees to make disclosures, without fear of retaliation. All matters raised will be investigated thoroughly by the Senior Management Team.
c.) We will establish effective reporting mechanisms to encourage employees, suppliers, and other stakeholders to report any instances of modern slavery.
d.) Whistleblower protection measures will be in place to ensure individuals who report in good faith are protected from retaliation.
e.) All reports will be treated confidentially, and appropriate actions will be taken to investigate and address reported cases.
4.6. Continuous Improvement
a.) To assess the effectiveness of our efforts in combating modern slavery and human trafficking, we will monitor key performance indicators (KPIs) such as the number of supplier audits, training session frequency and reach, incident reports, and supplier compliance rates. Specific targets will be set and reviewed regularly. The Board of Directors will evaluate progress at board meetings to ensure adherence and make adjustments as needed.
b.) We are committed to continuously improving our policies and practices to combat modern slavery. We will monitor and review our compliance with this policy on a regular basis.
c.) Feedback and recommendations from employees, suppliers, and other stakeholders will be actively sought and considered for improvement. We provide multiple channels for feedback, including anonymous suggestion boxes, surveys, and appraisals.
4.7. Communication and Transparency
a.) This Modern Slavery Policy will be made readily available to all employees, suppliers, and stakeholders.
b.) We will communicate our commitment to eradicating modern slavery to our stakeholders through various channels, such as our website, contracts, and reports.
