Modern Slavery and Human Trafficking Statement
This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by NAK Consulting Limited (“NAK”) to prevent modern slavery and human trafficking in our business and supply chain.
NAK seeks excellence in every aspect of our business and strives to ensure the highest standards of professionalism, integrity and ethical business practice. We are committed to conducting our business in a lawful manner and this includes engaging with our suppliers to ensure that they share our high standards.
We fully support the objective of the Modern Slavery Act of 2015, which requires businesses to set out what steps they have taken during the financial year to ensure that modern slavery is not occurring in their supply chains and in their own organisation.
Structure of Organisation
NAK is an independent and rapidly growing Managed IT Services Provider. Our focus is on delivering value-add services that allow our clients to optimise their investment in technology and people. We achieve this by taking the time to understand our clients’ unique challenges and objectives before designing and delivering the right, sustainable solution.
We have established a number of key partnerships and alliances, with suppliers, providers and service partners – all chosen because they actively contribute to a key aspect of our operations. We foster long-term relationships with these key partners and avoid making demands that might lead to them violating human rights legislation.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our modern slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships in addition to implementing effective due diligence to ensure that modern slavery is not taking place anywhere in our supply chain.
Responsibility for the Company's anti-slavery initiatives is as follows:
Policies: The Human Resources department is responsible for the development of policy, this being the current policy, and any necessary alterations to the same which is then approved by the Senior Management Team, before being communicated to staff and relevant suppliers.
Risk Evaluation: Responsibility for monitoring human rights and reviewing slavery risk is managed by the Senior Management Team.
Investigations/due diligence: The Operations, Finance and Human Resources Departments are responsible for appropriate investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
Training: All employees are required to familiarise themselves with this statement and with the Modern Slavery Awareness and Victim Identification Guidance. This is available on the Company’s HR System.
The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
Whistleblowing policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, of the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can make confidential contact with line managers and or senior management.
Employee code of conduct: The Company's code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating and managing its supply chain.
Procurement code of conduct: The Company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Serious violations of the Company's supplier code of conduct will lead to the termination of the business relationship.
Recruitment policy: The Company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
Anti-Bribery Policy: Our Anti-Bribery and Corruption Policy details our zero-tolerance approach to bribery and corruption and commitment to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. This policy applies to all individuals working for or on behalf of NAK, in any capacity.
Supply Chain Management
To ensure that the wider NAK service offering is in accordance with the direction of the policy on aspects of Modern Slavery, NAK has placed a flow-down obligation on all suppliers of services and goods whereby the provisions of the Modern Slavery Act are a contractual obligation. This will ensure that any future statements made by NAK are supported by the provision of relevant facts, information and accounts from our supply chain so that NAK can be confident of zero child and forced labour use within our supply chains.
NAK shall take responsibility for this statement which will be reviewed and updated as appropriate.
NAK is committed to ensure modern slavery does not exist within its organisation by improving its current practices, adapting existing procedures, creating new policy and continuing to educate its employees. The board of Directors have set targets for the forthcoming year which include the following;
To adapt and improve existing key policies and procedures as necessary to address modern slavery issues
To provide training to our employees on identifying any potential unlawful or unethical conduct within our operations and supply chain and how to report their concerns via NAK’s Whistle Blowing Policy
To ensure that all applicable sub-contractors have a signed statement and policy to abide by the Modern Slavery Act or for smaller organisations to agree to comply with the policy and procedures of NAK
To audit our policies and procedures to ensure effectiveness and best practice in addressing risk of modern slavery within our operations
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes NAK’s Modern Slavery and Human Trafficking Statement for the financial year ending 31st March 2020.
This statement was approved by NAK’s Managing Director, Jonathan Green on Thursday 5th September 2019.
People are NAK’s most valuable asset and we recognise that appropriate training on Modern Slavery and Human Trafficking will increase awareness as well as mitigate risk within the business and our supply chain. During 2019, we will continue to train our staff through face to face sessions utilising the Modern Slavery training resources available directly from HM Government: