MODERN SLAVERY STATEMENT 2022/2023
Novatech Ltd. is committed to ensure slavery and human trafficking does not exist within our employment practises or supply chain.
Under the Modern Slavery Act 2015 (the Act), we are dedicated to ensuring that human trafficking, slavery, forced or compulsory labour and/or servitude does not take place in our business or our supply chains.
Our structure and supply chains
Novatech is based in Portsmouth, Hampshire and has 116 employees. We are predominantly UK-focussed, with approximately two thirds of our business coming from the SME, education and defence sectors and the remainder of our sales coming from retail.
Operating in the IT sector, we source IT hardware and peripherals internationally, from global manufacturers. We custom-build, design, install and manage IT infrastructures to UK B2B and B2C markets. In doing so, we work with over 350 suppliers who are largely based in the UK (over 95%), with the remainder of our supply chain from Europe, USA and the Far East. We therefore consider that there is a relatively low risk of modern slavery and/or human trafficking occurring within our supply chain, however we understand that there is still a risk and strive to ensure that we have the right procedures and practises in place to be able to operate ethically.
Due diligence and effectiveness in combating slavery and human trafficking
As part of our commitment to identify and mitigate risk we have several strategies in place.
Suppliers
We undertake stringent processes to ensure we only use suppliers who share our commitment to ethical practices. By working to secure a transparent supply chain through operating due diligence, we seek to prevent modern slavery from occurring by:
• Fully committing to our Supplier Code of Conduct. We expect all suppliers to meet the provisions set out within this.
• Having a clear Supplier Application process in place for supplier approval.
• Obtaining Modern Slavery statements from suppliers, where available.
• Vet suppliers so far as is possible of their own compliance with the requirements of the legislation.
• Routinely analyse our supply chain, a task which is carried out at senior level, by the Purchasing Manager and Finance Director.
• Removing suppliers from our Approved Suppliers List after 12 months of inactivity. Suppliers will have to complete the registration process again to re-join.
Employees
We are proud to be a fair and ethical employer, promoting equality in everything we do. We do not consider there to be a high risk of slavery or human trafficking within our workforce, however we have the following in place:
• A robust recruitment process, incorporating a recruitment policy, 'right to work' document checks, contracts of employment and ensuring everyone employed is 16 years old, or above.
• A comprehensive Employee Handbook which has a range of policies and procedures to support the prevention of modern slavery from occurring in our workplace.
• Creating an awareness on the Modern Slavery Act and human trafficking, offering training to essential roles.
• A whistleblowing policy and procedure to honour our responsibility to protect whistle-blowers when highlighting any risk of slavery or human trafficking at Novatech.
• Company Values that set the parameters for how we expect people to interact with colleagues, partners, and customers.
• Disciplinary policy and procedures to ensure those who act unethically or do not always comply with legal requirements.
COVID-19 / Remote and Hybrid Working
Due to the COVID-19 Coronavirus pandemic, we enabled most of our employees to work from home and continued to work remotely since 2020, with hybrid working launched in 2022 which sees our remote workers have a mix of home and office working. Both internal and external meetings that would have normally been conducted face to face have gone ahead virtually since the pandemic hit, we are now moving to face to face meeting, where relevant but video conferencing still play a big part in what we do. We remain committed to ensure we uphold the same level of due diligence as we would have pre-pandemic.
The Future - 2022/2023
Whilst we have developed robust practises over the years to manage our stance to tackle modern slavery and human trafficking, we will continue to uphold the highest standards on this by:
• Reviewing the modern slavery and human trafficking policy
• Reviewing our recruitment policy and employment checks to ensure we remain vigilant in our employment practises
• Review the list of key "at risk" roles within the business to undertake our e-learning training on anti-slavery and human trafficking, training (including any refresher training). This ensures our people remain vigilant and have up to date knowledge.
• Review and update our modern slavery statement and other relevant policies of key suppliers, as part of our assessment for supply chain risks.
• Reviewing (and updating as needed), our Supplier Code of Conduct.
Novatech takes responsibility for this Statement and its related objectives, and we will review and update it in accordance with the Act.