This statement is published pursuant to Section 54 of the Modern Slavery
Act 2015. It outlines the position of, and steps taken by, BTS to prevent modern
slavery and human trafficking taking place within our business and supply
Introduction We understand that modern slavery encompasses slavery, servitude, forced
labour, human trafficking, and that it is a growing global issue. BTS has
a zero-tolerance approach to any kind of modern slavery within our organisation
or supply chains. We all have a responsibility to be alert to the risks within
our business and supply chains and will ensure that effective controls are in
place to safeguard against any form of modern slavery taking place within our
business and supply chains.
organisation and supply chain We are an
independent software vendor
operating solely within the UK. We operate out of our headquarters which is
located at our registered address, and we have 6 staff working from home. Our
supply chains are relatively simple and consist of UK wholesale or retail
suppliers of infrastructure, equipment, labour and materials relating to
software production/support and office administration.
slavery and human trafficking We are
committed to ensuring that there is no modern slavery or human trafficking in
any part of our business or in our supply chains. This 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 slavery and human trafficking is not taking place anywhere in our
business or within our supply chains.
diligence Although we
consider ourselves to be a ‘low risk’ business as regards slavery and human
trafficking, we foster a culture that encourages the identification and
reporting of any such risks within our business.
We have adopted the following processes as part of
our initiative to identify and mitigate the risk:
1. We identify, assess and monitor potential risk areas in our supply chains, ensuring that our larger and higher risk suppliers display statements on their websites that they are complying with the Act or equivalent local legislation 2. We raise any concerns with suppliers with a view to obtaining confirmation of adherence 3. We protect whistle blowers 4. We recruit employees either directly or through recruitment agencies who are members of the Recruitment and Employment Confederation (we do not recruit from outside the UK or use agency workers) 5. We avoid purchasing practices that could create supplier pressures leading to modern slavery such as short lead times, late payments, aggressive pricing, unfair penalties 6. We ask all employees to report concerns and ensure senior management act upon all concerns raised
provide appropriate training to ensure that employees understand the risks of
modern slavery and human trafficking within our business and supply chains.
Key performance Our Modern Slavery Act Statement and Policy will
continue to be reviewed and developed as part of the Company’s regular
Corporate Governance agenda.
Approval This statement has been approved by the BTS Board on 1 April 2019.