Modern Slavery Statement
Version 1.1 – 2nd April 2018
- A) ORGANISATION
This statement applies to all companies within and associated to Optima Systems Ltd (referred to in this statement as ‘The Group’). The information included in the statement refers to the financial year 2018-2019.
- B) ORGANISATIONAL STRUCTURE
The Group operates primarily from its main UK site in Crawley, West Sussex with control coming from a Board of Directors. The Group also has a satellite office in Malmo, Sweden from where much of R&D work is carried out. The Malmo office is controlled by a similar Board of Directors who report back up to the UK for financial and associated legal matters.
The main activities of The Group relate to software development which constitutes the majority of all the work undertaken. Within the UK there are additional activities related to IT Support and Web-Site design.
As demand for The Group’s services are consistently high throughout the year staff are employed on a permanent basis and are therefore not seasonal.
The labour supplied by The Group in pursuance of its operation is carried out in the UK, Sweden and USA
- C) DEFINITIONS
The Group 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 of 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 Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Group 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 Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and Sweden, and in many cases exceeds those minimums in relation to its employees.
- E) SUPPLY CHAINS
In order to fulfil its activities, The Group’s main supply chains include those related to Computer software of varying types and computer hardware, again of varying types. We understand that The Group’s first-tier suppliers are intermediary traders and therefore have further contracted relationships with lower-tier suppliers.
- F) POTENTIAL EXPOSURE
The Group considers its main exposure to the risk of slavery and human trafficking to exist in the computer hardware supply chain where their production may involve the provision of labour in a country where protection against breaches of human rights may be limited.
In general, the Group considers its exposure to slavery/human trafficking to be relatively 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 Group 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 Group 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 Group has taken the following steps to ensure that modern slavery is not taking place:
- reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery
- reviewing supplier policies to ensure that they are up to date and relevant
- ensuring staff are aware of The Group’s zero tolerance policy toward modern slavery
In the event that modern slavery is exhibited or suspected by The Group originating from a supplier;
- The supplier is to be immediately suspended as an approved supplier
- Further checks made with the supplier to confirm or deny any suspicions
- If suspicions are founded, then the supplier is to be removed from our approved supplier list
- In addition, any customer or supplier found to be in breach of the Modern Slavery Act 2015, may have contracts which exist between The Group and the supplier cancelled
- H) KEY PERFORMANCE INDICATORS
The Group has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in The Group or its supply chains.
- All staff in The Group to be fully conversant with its modern slavery policy and signed off within the HR system that they have completed this task
- First-line suppliers to have their Slavery policies checked and monitored on an annual basis
- All suppliers used within the Group to be checked for overall quality and adherence to the Modern Slavery Act 2015. Suppliers who do not come up to the required standard will be removed from our approved supplier list until such time as they do
- I) POLICIES
The Group has the following policies which further define its stance on modern slavery:
[no further policies]
- J) TRAINING
The Group provides the following training to staff to effectively implement its stance on modern slavery
- Training on induction to The Group covering all our internal policies including modern slavery
- Training on induction to The Group to explain what we are looking for when considering a new supplier to add to the approved supplier list
- An annual refresher for all staff to review and sign off that they have read and understood all sections of the staff and company manuals
- K) SLAVERY COMPLIANCE OFFICER
The Group 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 Group 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.
Date of approval 2nd April 2018
Signed Paul Grosvenor
(Slavery Compliance Officer and Managing Director)