Modern Slavery Statement

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Modern Slavery Statement

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 chains.  
  
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.


Our 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.


Policy on 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.


Due 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


Training

We 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.