Modern Slavery Statement

Modern Slavery Statement for UKCloud Ltd and Virtual Infrastructure Group Limited

UKCloud Ltd (UKCloud) is wholly owned and controlled by the Virtual Infrastructure Group Limited (VIG - company number 08099285) whose registered office is Hartham Park, Corsham, Wiltshire SN13 0RP. All of VIG’s business activities are conducted by UKCloud.

UKCloud Health and UKCloudX are divisions of UKCloud.

UKCloud is a British company providing highly secure cloud services exclusively to the UK public sector. Customers include the Ministry of Defence, the Home Office and many other public-sector bodies that hold sensitive data. As a UK company, our cloud platform is only hosted in the UK, and our services have been accredited by NCSC on behalf of our customers as suitable for data at OFFICIAL (including OFFICIAL-SENSITIVE) level.

Pursuant to the Modern Slavery Act 2015

The Modern Slavery Act 2015 came into effect on 29th October 2015. This law requires manufacturers and retailers doing business in the UK which supply goods or services and have an annual turnover exceeding £36 million to disclose information regarding their policies to eradicate slavery and human trafficking from their supply chain and within their business.

UKCloud takes its responsibility in this area very seriously and we have implemented robust controls and checks to ensure full and ongoing compliance with this important legislation.

UKCloud’s Supply Chain

UKCloud maintains published policies that strictly prohibits the use of slave labour or human trafficking activities in its direct supply chains. UKCloud’s Environmental & Social Risk Policy Framework, UKCloud General Terms of Purchase and the UKCloud’s Supplier Capability Assessments, all state the company’s commitment, its ethical principles and associated expectations from its supply chain.

All policies are available on request.

Due Diligence

UKCloud requires its key and strategic suppliers to complete an annual Supplier Assessment which is then reviewed and risk-assessed to ensure that they are compliant with the Act. Further, our Terms of Purchase place an obligation on our suppliers to warrant that they and their sub-contractors also comply in full with the Modern Slavery Act 2015 and other key legislation.

Our internal audit and compliance team will conduct regular reviews and report to the Leadership Team using key performance indicators.

Supplier Non-Compliance

UKCloud has a zero-tolerance policy towards Suppliers who fail to enact the laws banning forced labour, slavery and human trafficking. Our agreements enable the termination of suppliers for a single violation.

Written Policies and Procedures

UKCloud’s Environmental & Social Risk Policy Framework details the rules and procedures by which all personnel should respect and treat their fellow employees. Human rights include normal expectations arising from the sanctity of life, including the provision and exercising of civil, political, economic and social rights. We respect and actively support:

Employee Training

UKCloud complies with a comprehensive set of employment and personnel-based policies and procedures, as well as all relevant employment legislation, covering the Modern Slavery Act 2015. All employees are made aware of their responsibility to comply with formal policies and procedures, and regular training is provided to reinforce this message.

Human Rights

UKCloud undertakes regular reviews to ensure that all areas of its business are compliant with its acceptable ethical and international human rights standards, and that all employees are treated in a fair, transparent and respectful manner. This includes adherence to the UK’s Working Time Directive and the Minimum Wage.

Policy on actual or potential breaches

UKCloud’s Environmental & Social Risk Policy Framework states that in the unlikely event of an actual or potential breach of the Anti-Slavery Act and Human Trafficking Act, related Company policies and procedures, or should clarification on any matter relating to the respect and support of this be sought, the Chief Executive Officer is to be consulted.

Approval for this statement

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 ending 2021.

William Ginn,

Director and Chief Financial Officer,

on behalf of the Virtual Infrastructure Group Limited Board.

03/03/2020