MODERN SLAVERY STATEMENT

The purpose of this Modern Slavery Statement is to ensure that the company complies with the Modern Slavery Act 2015 and that we are putting strict measures in place to ensure that modern slavery is not part of any of our business operations. This includes our supply chains, goods, and services. This statement sets out the steps we are taking to continually develop our procedures and to check our compliance.

“Modern slavery” is a term which covers slavery (where ownership is exercised over a person); servitude (which involves the obligation to provide services imposed by coercion); forced or compulsory labour (which involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself voluntarily); and human trafficking (which concerns arranging or facilitating the travel of another with a view to exploiting them, even where the person consents to the travel).

Overview

An overview of our organisational structure, key business activities, and supply chains is as follows:

  • Frontier operates in the IT sector
  • The business model is via direct sales, partners, and vendors
  • The organisational structure is a functional structure where each portion of the business is grouped according to purpose: Operations, Technical, Sales, Corporate.
  • Our suppliers are based in the UK, which is classed as a low-risk country in terms of modern slavery

We work closely with our main suppliers and customers, with our employees to ensure the highest level of compliance within the IT sector.

We embrace social responsibility as part of our current ISO certifications: 9001 (Quality Management), 14001 (Environmental Management), 27001 (Information Security Management).

Responsibilities

  • The Managing Director of Frontier Technology is responsible for overseeing our efforts to help to eliminate modern slavery and for monitoring progress against the key performance indicators (KPIs) contained in this document.
  • The HR Manager is responsible for ensuring that all recruitment and terms and conditions of employment comply with statutory requirements and that any agencies used are appropriately checked and committed to ethical standards.
  • Managers are responsible for upholding our “core values” and for ensuring that employees who work for them also behave in accordance with these.
  • Our supply team is responsible for ensuring that appropriate checks are made prior to placing any orders with new suppliers, and that existing key suppliers are audited from time to time to ensure continued compliance.
  • Our Commercial Director works with our major customers to provide them with appropriate information on our modern slavery initiatives and to gain suggestions and feedback.

Documentation

We have the following policies in place for employees:

  • Business Ethics and Integrity Policy
  • Corporate Social Responsibility Policy
  • Grievance Policy
  • Environmental Policy
  • Equal Opportunity Policy
  • Recruitment and Selection Policy
  • Whistleblowing Policy

Copies are available on the HR portal and on the network.  All policies are reviewed and updated on an annual basis.

Employees are reminded of the policies from time to time and notified of any updates.

Risk assessments

  • We consider that the main areas of risk of modern slavery within our business and supply chain as follows: countries producing IT goods/products (internal/foreign migrant workers, refugees, low skilled workers, and women).

Actions we are taking

  • We have taken the following specific actions as part of our drive to eliminate modern slavery. Any employee who has any further suggestions regarding actions that may assist us in our overall aim, or concerns about areas of potential risk, should raise these with their Line Manager or the HR Manager.
  • Our recruitment and selection policy aims to assist all those involved in the recruitment process to comply with equal opportunity.
  • All new employees are recruited directly, and we conform to the ethical standards set out in ISO 9001. Right to work checks are conducted prior to joining, and we check with all new recruits that they have not been required to pay any fees to gain work with us, and inform them of the procedures that should be followed should they wish to leave our employment.  In addition, we check that their passports have not been withheld and that they have not been required to sign any agreements with any third parties in respect of our offer of employment.
  • We embrace our corporate social responsibility as defined in the Corporate Social Responsibility Policy.
  • Suppliers are required to self-certify their compliance with the Modern Slavery Act.
  • Our main suppliers are requested to inform us of the steps that they are taking to eliminate modern slavery.

Penalties for breach

  • If a supplier is found to be involved in any form of modern slavery, its contract will be terminated either immediately or on its due renewal date, depending on the severity of the breach. We may also report any suspicions of criminal activity to the police.
  • If it is established that an employee has acted in breach of any of our policies, or is aware of, has condoned, or failed to report any suspicion of modern slavery within our business or supply chains, they will be subject to our disciplinary procedure.

Training

  • Employees and managers are informed of any updates to our policies via the HR portal.

If you would like to find out more about the above, email us at hr@frontiertechnology.co.uk