Slavery and human trafficking statement

Introduction

As a leading global data protection consultancy and DPO service provider, we have a responsibility to use the influence we have, through delivering some of the worlds most complex data protection, cyber security, and technology projects, to make a positive change for those who need it most.

A key part of this is our approach to addressing modern slavery and more widely respecting human rights. We reject modern slavery in all its forms, including servitude, forced or compulsory labour, child labour and human trafficking. We recognise that there are risks of modern slavery in every country and any industry and aim to work only with suppliers whose policies and procedures support our own approach.

This statement confirms our compliance with Section 54 of the UK Modern Slavery Act 2015. In setting our policies and processes we aim to follow best practice as well as the UK Government guidance ‘Transparency in supply chains’. In addition to publishing this statement on the IG-Smart Ltd website, we will also publish it on any associated websites to promote our commitment to this agenda.

This statement covers the whole of  IG-Smart Ltd and its worldwide operations.

We operate globally with one corporate set of policies, directives and requirements through a common online business management system. Through this approach, all our colleagues in the IG-Smart Ltd, whether employed in the UK company or around the world are required to comply with the UK Modern Slavery Act 2015 as well as any national legislative requirements.

Our supply chain

We recognise our responsibilities to ensure that our supply chain complies with International Labour Organisation conventions and have proper respect for the people supplying services to them. We are committed to achieving the ethical standards we set for ourselves with our supply chain and continue to work towards full transparency. Modern slavery aspects are included in our standard supplier and joint venture contracts in the UK.

The modern slavery risks the business faces can broadly be divided into the following categories of supply chains in our business operations:

1. Organisations providing resources or services to support the delivery of our business, such as suppliers of personal protective equipment, office supplies, catering organisations, accommodation and travel companies.
2. IT and other office equipment, such as furniture

The above groups can be further subdivided into labour that is:

• Directly employed (IG-Smart Ltd being the contracting party)
• Sub-contracted, where we employ a service agency who is the contracting party
• Associated labour, whereby our joint venture (JV) partners are the contracting party, or they sub-contract to agencies to provide labour

In all cases we seek to ensure that our purchasing practices do not create pressure on our suppliers that could lead to modern slavery for example, avoiding aggressive pricing that does not consider production costs, late payments or imposing unfair penalties.

In our UK and Europe region all our approved suppliers are held on a central database which staff can consult prior to engagement. Those we have identified as higher risk such as our central UK facilities management contract, our personal protective equipment supplier and our furniture suppliers are subject to additional questions at tender stage and during regular contract reviews. We also carry out some spot checks for payments of a living wage and audits for working conditions at manufacturing facilities.

Our policy

Our approach to respecting people and our suppliers is also embedded in our policies on slavery and human trafficking, equality, diversity and inclusion, ethics, human resources, risk treatment, procurement, safeguarding, and social responsibility.

Due diligence process

As a predominantly professional services body, the vast majority of IG-Smarts direct employees are not considered vulnerable, or at risk from modern slavery. In relation to slavery and human trafficking in our business, we:

• Employ individuals through an interview process, whether they are full-time employees or contract staff. This process seeks to confirm individuals share our corporate values, have a right to be employed for a specific job, are not breaching immigration regulations; have the necessary competence and aptitude for the position and are applying to work for us through their own free will.
• Seek to provide a living wage for all directly employed staff.

In our supply chain, we evaluate all potential and existing suppliers using a standard questionnaire to identify competence, compliance with our values and standards and to ensure they are addressing slavery and human trafficking risks. This assessment is repeated periodically. The process is supported through our procurement processes. We are currently reviewing our global approach to procurement to identify best practice and strengthen this area in the future.

Due diligence on clients and suppliers is undertaken through combining our previous experience of working with the organisation, our local knowledge of them and the information surfaced through Know Your Customer checks. This consists of an initial web- based search on a company and its affiliates, with a more comprehensive review available if needed.

We verify that we hold up-to-date and accurate information about our suppliers, supported by our supplier questionnaire prior to engagement. We check they comply with the requirements in our policies on modern slavery, ethics and anti-bribery, and they divulge essential financial and structural information to us. Following appointment, suppliers are assessed annually via a formal record of performance.

Risk assessment

As stated, as a professional services organisation, our risks associated with slavery and human trafficking of direct employees are generally low. Our professional staff have tertiary education, are often members of professional organisations and command significant levels of compensation in line with market norms.

It is acknowledged that our risks related to modern slavery vary between the countries and sectors we work in.

We have carried out a preliminary geographic risk assessment which we will continue to develop over the coming years. We are currently working on how we might use the Global Slavery Index to identify the specific areas in our supply chain that might pose a higher risk for modern slavery, looking at both location and sector.

To support the business we have produced best practice guidance for our project managers and teams to help them identify key areas of risk and to implement appropriate control measures to mitigate the risks. This has been integrated into our health and safety risk assessment process and training has been provided to our global safety managers and project safety advisors to support project staff. The areas of risk identified can be broadly grouped as:

• Outsourced low wage jobs, such as office cleaners, drivers and support staff
• Our commodity purchasing supply chain eg personal protective equipment, IT equipment, office furniture, tea and coffee, where unskilled labour is prevalent
• The construction related supply chains of our partners and clients around the world
• Staff untrained in recognising the signs of modern slavery
• Working with joint ventures (JV) and sub-consultants
• Failure to report and investigate suspected modern slavery issue

Effectiveness of our approach

As we deem the risk of slavery and human trafficking in our own business to be low, we monitor the performance of our suppliers in supporting us to meet our policy commitment and the services they provide to us. We also monitor our own compliance with our employment and procurement processes. In addition, we are audited around the world by third party organisations both for compliance with our internal business processes and with quality standards. We are confident this approach is appropriate to managing our risks for our tier one suppliers.

Speaking up

Our Speak Up helpline is a comprehensive and confidential internet and telephone-based reporting tool. We have strict processes in place which are published as part of our business management system. The service is promoted through campaigns within the company. It is accessible to anyone, including all tiers of our supply chain. Reports are treated confidentially and can be raised anonymously where local legislation allows. During 2020 we did not receive any reports (internal or via Speak Up) related to modern slavery or human trafficking.

Training and awareness

We train all our staff on ethics and compliance with our values, directives and processes. We also provide training on people management and communications skills and these are directly aligned with our values. This creates a strong culture of tolerance of others, transparency in decision-making and mutual respect, that supports our training module on Modern Slavery which is available to all staff.

The above statement has been approved by the Executive Board of IG-Smart Ltd and is signed on their behalf by Mr Michael Abtar, Managing Director.

Michael Abtar
Oct 2021