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Ultima  Business Solutions Limited - Slavery and Human Trafficking Statement for the Financial Year 2016

 

1.      Introduction

This statement is issued in accordance with the requirements of Section 54, Part 6 of the Modern Slavery Act 2015 and identifies the steps Ultima has taken to ensure that slavery and human trafficking does not take place within our business and also that of our Suppliers.

2.      Organisation Structure and Supply Chain

Ultima is a wholly United Kingdom based company providing Information Technology infrastructure solutions to corporate businesses within the UK.  A small amount of our business is conducted offshore, predominantly (but not limited to) Europe, but this accounts for less than 5% of our revenue.  We are headquartered in Reading with a second office in London and employ approximately 450 people.

Our offerings include the supply of hardware, vendor software licences and asset management, hardware maintenance, professional services (engineering, consultancy and project management) and managed services (remote monitoring and management of systems, on-site and remote help desks, third line telephone support).

We use our supply chain to procure hardware for resale to our customers together with vendor software licences; maintenance services; network & communications services and datacentre services.  We work with reputable UK distribution channels, but from time to time have a requirement to source offshore.  We appreciate there is an increased risk in the latter case and take additional steps to qualify any foreign suppliers before engagement.

We endeavour to appoint suppliers that we can trust, respect and that provide transparency.  We require our suppliers to meet our high expectation of standards and business practices.  We expect our suppliers to comply with applicable laws and regulations wherever they may operate and in turn to promote and expect similar standards from their own suppliers

3.      Responsibilities

Our policies relating to Slavery and Human Trafficking are implemented and maintained under the control of our HR department.

Within our company the primary stakeholders for driving the policy are:

a. The Chief Executive Officer
b.  The HR Manager
c.  The Commercial Director
d.  The Group Finance and Legal Officer

Responsibilities for ensuring that policies are implemented are defined below:

a.  The HR Manager ensures that regular meetings of the stakeholders are held to ensure compliance, assess new and potential risks, training is maintained, changes to policy to meet changing regulatory practices and communication to staff and suppliers is maintained.  They are responsible for risk assessments, investigation, due diligence and training.
b.  The Commercial Director is responsible for developing the appropriate controls and checks are in place for the appointment of new suppliers and that existing suppliers are reviewed annually for continuing compliance with the controls.
c.  The Group Finance and Legal Officer will ensure our ongoing compliance with the act and maintain awareness of any changes that may effect Ultima with a view to their implementation.
d.  The Chief Executive Officer will ensure that the Key Performance Indicators are achieved and the overall effectiveness of the policies implemented.

4.      References to other policies

a.  Ultima Corporate Compliance Policy
b.  Ultima Employee Handbook – whistleblowing
c.  Ultima Corporate Social Responsibility Policy

5.      Due Diligence Checks on Suppliers

a.  New Suppliers

  • Initial selection based upon knowledge of supplier, that is, typically a largely UK based organisation, established operation, good track record
  • D&B check performed to confirm financial stability
  • Personal visit or visual check of registered office location
  • Companies House look-up and verification
  • ICO registered company  check
  • Questionnaire issued to supplier and results reviewed.  This includes specific questions regarding Slavery, Human Trafficking and employment of young persons (website check to confirm Slavery statement).

b.  Existing Suppliers

  • Issue revised questionnaire of major points in new supplier questionnaire including those questions related to Slavery, Human Trafficking and employment of young persons.

6.      KPI Overview

1.  The Commercial Director will be measured for the effectiveness of vetting of all new suppliers before their appointment
2.  The Commercial Director will be measured for the annual review of existing suppliers for continued compliance.
3.  The HR Manager will be measured for the effectiveness of training of any staff with a role requiring dealing with suppliers.
4.  The HR Manager will be expected to hold regular, minuted meetings of the stakeholders.

 

This statement has been approved by the Executive Board of Ultima.

Scott Dodds

Chief Executive Officer

Ultima Business Solutions Limited

 

1st October 2016