Modern Slavery Statement
Modern slavery is a crime and a gross violation of fundamental human rights. It takes various forms, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and are fully committed to preventing modern slavery and human trafficking in our corporate activities. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We all have a responsibly to be alert to the risks, however small, in our business and in the wider supply chain.
Organisation Structure and Supply Chains
WCL(UK) Ltd, trading as Everything ICT, is a limited company controlled by a Board of Directors and currently employing 19 UK-based staff. We operate a national public sector buying framework for ICT, operating via a growing network (currently 200+) of subcontracted suppliers to deliver goods and services to customers across a wide range of buying categories.
Definitions
We consider that modern slavery encompasses:
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Human trafficking;
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Forced work, through mental or physical threat;
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Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
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Being dehumanised, treated as a commodity or being bought or sold as property;
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Being physically constrained or to have restriction placed on freedom of movement.
Commitment
Everything ICT acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. We understand that this requires an ongoing review of both our internal practices in relation to our labour force and our supply chains.
We have a zero tolerance policy towards modern slavery. We will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
The labour supplied to Everything ICT in pursuance of the services it provides is carried out wholly within the United Kingdom.
No labour provided to Everything ICT in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. We adhere strictly to the standards required in relation to our responsibilities under relevant employment legislation in the United Kingdom and in many cases we exceed minimum standards in relation to our employees.
We offer employment contracts on a guaranteed hours basis only. No offers of employment are made on a zero hours basis.
Everything ICT employees are offered a competitive remuneration package. Part-time and fixed-term employees within Everything ICT are provided with the same pro-rata contractual entitlements as full-time and permanent employees.
Potential Exposure
Everything ICT considers its exposure to modern slavery to be very limited as we only source goods and services from UK-based companies. Nonetheless, we have taken steps to ensure that such practices do not take place in our business nor the business of any organisation that supplies goods and/or services to us or via us to our clients.
In the operation of its business, our main supply chains are those related to the provision of goods and services. We consider our sole exposure to the risk of slavery and human trafficking to exist in our supply chains, and chiefly among those suppliers who deal with, or source products or components from, third party companies based outside the UK.
Due Diligence Processes
In accordance with section 54(4) of the Modern Slavery Act 2015, we carry out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in our supply chains by requiring all our suppliers to self-declare and to provide copies of their own Modern Slavery policies or statements, as part of their initial application to becoming a Everything ICT Partner. The self-declaration must include a stipulation that suppliers undertake similar due diligence within their own supply chains, as required by legislation.
We have not, to our knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.
We monitor reports of modern slavery and will cross reference such reports with our own supply chain. We will seek immediately to discontinue business with any supplier found by enforcement authorities to be involved in modern slavery.
We encourage use of our own whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.
Awareness and Training
Upon commencement of employment, all employees are made aware of Everything ICT’s policies relating to the standards of behaviour we require from them, including this policy on modern slavery and the need to be vigilant when dealing with suppliers.
Assessment of Effectiveness in Combating Modern Slavery
To ensure effectiveness in combatting modern slavery, we maintain an accurate supplier list including contact details and copies of supplier policies and statements. We ensure action is taken in response to reports of modern slavery in our supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with this policy. To date there have been no reports that any of Everything ICT’s suppliers have been involved in activities covered by the Modern Slavery Act.
Group Compliance Manager
Everything ICT has a nominated individual (HR Director Nigel Hall) to whom all concerns regarding modern slavery should be addressed. The HR Director undertakes an annual review of our obligations towards eradicating modern slavery within our organisation and supply chains.
Risk Assessment and Review
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010. It is reviewed by the Everything ICT Board in each financial year and was last reviewed at a board meeting held on 14 September 2023.