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Slavery and Human Trafficking Statement

Introduction from the Managing Director

This human trafficking statement is made pursuant to Section 54 of the Modern Slavery Act 2015 'Transparency in Supply Chains'.

We are committed to improving our practices to combat slavery and human trafficking. As embodied in Trams Group’s (the Group) core values, the Group operates a responsible business, which is committed to acting with integrity and maintaining the highest professional and ethical standards in all our business relationships, including our supplier relationships. The Group has a zero-tolerance policy towards slavery and human trafficking and we require our suppliers to take a similar approach.


1. Organisation's structure

We are a supplier and value-added re-seller in the technology sector. The Group’s ultimate parent company is Trams Limited, which has its head office in England. The Group has over 40 employees and operates in the UK.

Our business

Our business is organised into 3 business units:

Sales: Supplying a broad range of commodity IT Hardware & Software

Consultancy: Advising and working with clients on their IT infrastructure, data storage and media content management strategies and helping them design performant IT workflows & systems.

Service & Support: Providing on-site and remote support of customer’s IT infrastructure

Our supply chains

Our supply chains include the purchase and re-sale of technology goods and associated support services.


2. Our policies on slavery and human trafficking

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 anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place anywhere in our supply chains

Further, the Group has the following policies published on our intranet (which is accessible to all employees):

  • Whistleblowing policy;
  • Health and safety policy;
  • Harassment policy prohibiting harassment and intimidation; and
  • Disciplinary policy prohibiting any threat of violence.

Our risk analysis

On the basis of the due diligence and analysis of the Group’s business and its supply chains carried out to date, we consider that it is currently at a low risk of slavery and human trafficking in both the context of its own business and its supply chains.


3. Due diligence processes for slavery and human trafficking

We have in place systems to:

  • identify and assess potential risk areas in our supply chains.
  • mitigate the risk of slavery and human trafficking occurring in our supply chains.
  • monitor potential risk areas in our supply chains.
  • protect whistle blowers.

As part of our initiative to identify and mitigate risk we:

  • act promptly where a compliance breach has been identified or flagged; and
  • continue to feed-back lessons learnt into the compliance risk management process.

4. Supplier adherence to our values and ethics

We have zero tolerance to slavery and human trafficking and we are committed to acting ethically, and with integrity and transparency, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within our supply chain.

We have in place a supply chain compliance programme. This programme is designed to:

  • identify and assess the potential risk areas in our supply chains; and
  • check that all of the Group’s suppliers are aware of and comply with the Modern Slavery Act 2015 and are transparent, accountable, auditable and free from ethical ambiguities
  • We also conduct due diligence on all suppliers before allowing them to become a preferred supplier (including due diligence relating to compliance with the Modern Slavery Act)

We expect all delivery partners, organisations within our frameworks and other companies that we engage with to ensure their goods, materials and labour-related supply chains are free from any form of modern slavery.


5. Training and Employees

We are an equal opportunities employer. Employee engagement is at the heart of our approach and we want to motivate and empower our employees to use their talents/skills positively, whether that be locally, regionally, nationally or ultimately at a global level.

Our employee policies and procedures set out our requirements on such issues as disciplinary, grievance, equal opportunities, flexible working, harassment and bullying, home and mobile working. We expect all employees to conduct business with honesty and integrity and we have a zero-tolerance approach to bribery and corruption.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our employees.

Within the Group’s business we have a very low level of migrant labour. All employees are paid at, or above, the living wage. The standard terms and conditions of employment for our staff provide for the freedom of the employee to terminate his or her employment at any time.


6. Our effectiveness in combating slavery and human trafficking

We have a compliance team, which consists of involvement from the following departments:

  • Directors & Shareholders
  • Audit and compliance
  • Human resources
  • Procurement
  • Sales

7. Further steps

Following a review of the effectiveness of the steps we have taken to ensure that here is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

  • review our contractual terms and conditions to ensure they are in keeping with good practice for companies with similar operations; and
  • continue the review and due diligence of our supply chain, focused specifically on Modern Slavery risks.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 2017.