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    Modern Slavery Statement

MODERN SLAVERY STATEMENT

 

A) Organisation
This statement applies to Premiertec Consulting Limited, trading as Claremont (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2020 /2021.

B) Organisational Structure
The main activities carried out by the Organisation is the provision of IT support and project services, as well as hosting solutions.  The Organisation is controlled by a Board of Directors.

The Organisation has 2 main offices in the UK – in Newcastle and in Guildford.  The vast majority of the Organisation’s service delivery is performed from resources’ homes, and where this is not otherwise performed from the Organisation’s offices, this will be performed at our Clients’ sites.  The Organisation also has a key supplier (Kogitas), which provides largely remote resources based from their offices (and homes) in Croatia.  Additionally, the Organisation provides hosting services from 3 data centres within the UK, though our key suppliers.  

C) Definitions
The Organisation 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, or 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.

D) Commitment
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. 

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, and in many cases exceeds those minimums in relation to its employees.

E) Supply Chains
In order to fulfil its activities, the Organisation’s main supply chains include those related to the supply of IT consultants and resources in the UK and Croatia.  Within the UK, where we cannot engage resources directly, we understand that the Organisation’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

F) Potential Exposure
Due to the nature of the services the Organisation provides (e.g. IT services within the UK and Ireland), the Organisation considers its exposure to slavery/human trafficking to be very limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it. 

G) Steps
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place: 

  • Updated our Supplier Relationship and Supplier Policies (to include our Supplier Questionnaires), to identify and manage potential risks in our supply chain;
  • Updated our template Supplier Agreements, to include termination powers in the event that the supplier is, or is suspected to be, involved in modern slavery.

H) Key Performance Indicators
The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

  • No medium or high risks are identified from the Organisation’s annual risk review of its controls in regards to modern slavery;
  • No medium or high risks are identified for any new Supplier engagements during a financial year in regards to modern slavery.

I) Policies
The Organisation has the following policies which further define its stance on modern slavery: Claremont Supplier Relationship Policy; Claremont Supplier Policy.

J) Training
The Organisation provides the following training to staff to effectively implement its stance on modern slavery: induction training.

K) Slavery Compliance Officer
The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation obligations in this regard.  

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Approved and signed by Daniel Berry, Compliance Manager at Claremont on 10th August 2020