Modern Slavery Act

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 seriously, and has implemented a number of 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.  UKCloud require all applicable suppliers to complete an annual Supplier Assessment which is then reviewed (and randomly validated) to ensure that they are compliant with the Act. Further, UKCloud’s Terms of Purchase also ask that the supplier warrant that they and their own downstream suppliers also fully comply with the Modern Slavery Act 2015.
  • All policies are available on request.

Supplier’s failure to comply

  • UKCloud has a zero-tolerance policy towards Suppliers who fail to enact the laws banning forced labour, slavery and human trafficking. UKCloud’s contractual agreements permit 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. UKCloud respects and actively supports:
    • the human rights of its employees, whether full-time, part-time, temporary or permanent
    • the human rights of those directly engaged by the Company, e.g. contractors and partners
    • the existence of rights at work, and a commitment to resolve employee grievances
    • the avoidance of complicity
    • the protection of vulnerable groups, and ensuring that no discrimination exists
    • the assurance that human rights are respected at all stages of the supply chain

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

William Ginn, Director and Chief Financial Officer.

26/04/2017