Modern Slavery Statement

Modern Slavery Statement

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Organisational structure and supply chains


Boxxe Limited (“boxxe”) is a privately owned entity incorporated in the UK. We provide corporate and public sector organisations with hardware, software, and services across a range of technologies including cloud, datacentre, workplace and security. Our customers trust our in-house teams to deliver consultancy and managed services which support and enhance a broad range of industry leading and innovative technology partners. We also work alongside several specialist external services partners to underpin and amplify our own teams. Whilst we have an office in York, our approximately 200 people are equipped to work anywhere in the UK. Our heritage is providing secure services to public sector organisations whilst also delivering technology solutions to small, mid-market and enterprise corporate customers. As sustainability is one of our core values, we are currently pending certification of B-Corporation status in the UK.


Introduction to the Modern Slavery Act

The Modern Slavery Act 2015 (the “Act”) requires each business in the UK with an annual turnover of over £36 million to publish a transparency statement which sets out the steps they have taken to ensure there is no modern slavery in their supply chain or within their own business. 

Our commitment, outlined in this statement, is made pursuant to the Act.

 
Our policy on modern slavery and human trafficking


We have an absolute zero tolerance policy to modern slavery. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our policy reflects our broader commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place within our business or supply chains.  


We understand that modern slavery encompasses:


1.    Forced or compulsory work, through mental or physical threat;
2.    Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
3.    Being dehumanised, treated as a commodity or being bought or sold as property; and/or
4.    Being physically constrained or having restriction placed on freedom of movement.


Commitment


1.    We acknowledge our responsibilities under the Act and we are committed to preventing slavery and human trafficking within our businesses and our supply chains. We understand that this requires an ongoing review of our internal practices and continual due diligence of our supply chains.
2.    As part of our zero tolerance policy, we will not enter into business, and will discontinue any current business, with any other organisation which knowingly supports or is found to involve itself in slavery, servitude or forced or compulsory labour.


We will strive to ensure that no labour provided to us in the provision of our services is obtained by means of slavery or human trafficking. As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our employees. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion. We adhere to all relevant employment legislation in the United Kingdom. 


Our due diligence processes


To ensure that this policy is adhered to, we implement the following processes:


1.    Engaging with all our major suppliers to convey the contents of this policy to them, and asking them to confirm they have read and understood our policy and will adhere to it;
2.    Surveying our suppliers to establish what steps, measures and practices they have implemented to prevent modern slavery occurring in their organisations;
3.    Introducing contractual provisions into our supply contracts where appropriate to confirm that our suppliers adhere to and accept our policy; and
4.    Discontinuing business with any supplier found to have been involved in modern slavery (upon us becoming aware of such).


To facilitate these processes, we maintain an accurate supplier list including key contact details. We also encourage the use of our whistleblowing policy to report any concerns regarding modern slavery. We will investigate any complaints thoroughly and provide protection to the whistleblower.


Our effectiveness in combating slavery and human trafficking


As our attitude to modern slavery is zero tolerance, we have not adopted key performance indicators as any instance of modern slavery or human trafficking in our supply chain would be an unacceptable breach of our policy.
However, we will monitor our internal compliance with this policy by recording:


1.    Which of our suppliers have read and agreed to adhere to our policy;
2.    Which of our suppliers have implemented their own policies and procedures with prohibitions against modern slavery; and
3.    Which of our suppliers place obligations on their own employees to comply with their modern slavery policies.


Where our suppliers do not yet have modern slavery policies and procedures in place, where appropriate we will ask for confirmation as to the likely timescale for their introduction. 
A failure to comply with this policy will result in the termination of our contract with the supplier.

 

Responsibility for our policy


boxxe’s Board of Directors are ultimately responsible for compliance with this policy, and the Board of Director’s are advised by the internal legal team. Any queries, questions or concerns regarding modern slavery can be addressed to both the legal team and the Board of Directors. The legal team will undertake an annual review of our obligations towards eradicating modern slavery within our organisation and supply chains.


Training


All our employees are instructed to read this policy and confirm their understanding and agreement to comply with our policy to help in the identification and prevention of modern slavery. This policy will be publicised internally to raise awareness. New employees will receive training on this policy as part of their induction process. In addition, all our employees responsible for compliance or procurement will be trained on the requirements of this policy. All employees are encouraged to identify and report any potential breaches of this policy.


Risk Assessment and Management


boxxe has a risk-based methodology in place to ensure its suppliers comply with the Act.  Given the nature and locations of our business, we consider ourselves to be at low risk of the potential for slavery or human trafficking. We also believe that our business model and strategy is unlikely to create material risks of slavery and human trafficking. We have a number of procedures in place which we consider to be effective to prevent modern slavery from occurring in our business or supply chains


Approval


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 financial year 2022 and is approved by the Board of Directors of Boxxe Limited.


Signed on behalf of Boxxe Limited by 

 

Phil Doye, CEO

September 2022

 

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