Modern Slavery Statement

MODERN SLAVERY STATEMENT

Organisational structure and supply chains

The Prodec Network Group of Companies includes Prodec Networks Ltd, Network 24 Ltd, Hosting Techniques Ltd and Smarter Interactive Ltd (“Prodec”).

Prodec is a leading provider of transformational IT products, solutions and services, which enable people to securely connect, communicate and collaborate without limitations.

We use a wide variety of local, national and international suppliers to source products, services, facilities and equipment for the operation of our business. In particular, we work with large information technology distributors and original equipment manufactures as well as leading software, network service and cloud service providers. Prodec recognise that the nature of our supply chain can make checking for illegal activity challenging. We understand that our first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers. However, as explained below, there are a number of checks and safeguards we will put in place to reduce the risk of modern slavery and human trafficking occurring in our supply chain.

Prodec’s modern slavery policy

Prodec has a 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 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 chains.

Prodec considers that modern slavery encompasses:

  • human trafficking;
  • forced work, through mental or physical threat;
  • being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
  • being dehumanised, treated as a commodity or being bought or sold as property;
  • being physically constrained or to have restriction placed on freedom of movement.

Commitment

Prodec acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015 (the Act). We understand that this requires an ongoing review of both our internal practices and continual due diligence of our supply chains.

Prodec will not conduct business and will discontinue any current business with any other organisation that 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. We will strictly adhere to the standards required of us in relation to our responsibilities under relevant employment legislation in the United Kingdom.

 

Our due diligence steps

To ensure that this policy is adhered to, Prodec will introduce and maintain the following processes:

  • Conduct impact assessments to identify which parts of our businesses and supply chains are most at risk from modern slavery;
  • Engage with all our major suppliers to convey the contents of this policy to them, and asking them to confirm they have read and understood this policy and will adhere to it;
  • Survey our suppliers to establish what steps, measures and practices they have implemented to prevent modern slavery occurring in their organisations;
  • Review and introduce contractual provisions into our supply contracts where appropriate to confirm that our suppliers adhere to and accept our policy; and
  • Discontinue business with any first-tier supplier found to have been involved in modern slavery.

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 and we will investigate any complaints thoroughly.

Our effectiveness in combating slavery and human trafficking

Prodec will monitor internal compliance with this policy by recording which of our suppliers:

  • have read and agreed to adhere to our policy;
  • have implemented their own policies and procedures with prohibitions against modern slavery;
  • 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, and where appropriate, we will ask for confirmation as to the likely timescale for their introduction.

Compliance

All of our employees are UK based, and we are compliant with the National Living Wage requirements. Our employees are instructed to read this policy and confirm 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 be required to read this policy and confirm understanding as part of their induction process.

Review

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and will be reviewed each financial year.

Signed:

Mark Lee

Chief Executive Officer

Date of approval: 21 September 2022