Modern Slavery Statement
A) ORGANISATION
This statement applies to I-Net Software Solutions (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year 2023-2024.
B) ORGANISATIONAL STRUCTURE
The Director oversees all departments, setting strategy, approving budgets, and representing the organization. The Software Development team delivers software solutions, led by the Project/Delivery Manager and supported by Business Analysts, Developers, and Testers. IT and Infrastructure ensures technical reliability, with a Delivery Manager, Networking Manager, and IT Support Team maintaining systems and networks.
HR, led by the HR Manager, handles employee policies and recruitment, while the Recruitment Team sources talent. Sales and Marketing drive growth through the Business Development Executive and Marketing Consultants. Finance and Accounts manage budgets, payroll, and compliance, ensuring fiscal stability. Legal and Compliance oversee contracts, regulations, and risk mitigation to support smooth operations.
The main activity carried out by the organisation is providing IT Managed services such as Infrastructure management, Helpdesk and Support Services, Cybersecurity Services, Cloud Services Management, Strategy and Consulting along with outsourcing resources for IT Projects such as Resource Allocation, Project Management, Software Development, Testing and Quality Assurance. The Organisation performs its activities at its office and its client’s offices. Demand is consistently high throughout the year and is therefore not seasonal. The labour supplied to the Organisation in pursuance of its operation is carried out wholly in the United Kingdom.
C) DEFINITIONS
The Organisation considers that modern slavery encompasses:
- Human trafficking;
- Forced work, through mental or physical threat;
- Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
- Being dehumanised, treated as a commodity or being bought or sold as property;
- Being physically constrained or to have restriction placed on freedom of movement.
D) COMMITMENT
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation.
E) SUPPLY CHAINS
In order to fulfil its activities, the Organisation’s main supply chains include those related to technology, infrastructure and tools, skilled workforce, knowledge resources, vendors and suppliers in the United Kingdom. The core components in our supply chain include human resources, technology resources, processes and methodologies.
F) POTENTIAL EXPOSURE
- The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in the below key areas –
- Recruitment Practices
- Hardware Supply Chains
- Low Skilled Labor in IT Support roles
- Temporary and Contract Labor
- Service Providers and Third-Party Vendors
- In general, the Organisation considers its exposure to slavery/human trafficking to be considerably high. Ixt has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
G) STEPS
- The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
- The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
- In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
- Reviewing our supplier contracts to include termination powers in the event that the supplier is, or is suspected to be involved in modern slavery;
- Ensure suppliers possess necessary licenses and certifications, such as ISO standards or ethical recruitment certifications;
- Develop a matrix to identify potential risks (e.g., non-compliance, financial instability, or fraud;
- Classify suppliers based on criticality to operations and their associated risk levels;
- Regularly audit suppliers to ensure adherence to legal, ethical, and operational standards;
- Collect feedback from candidates regarding their experience with suppliers to identify unethical practices or inefficiencies
H) KEY PERFORMANCE INDICATORS
- The Organization has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organization or its supply chains.
1. Compliance KPIs:
- Supplier Audits Completed (%):
- Percentage of suppliers audited annually for compliance with anti-modern slavery laws and standards.
- E.g., Target: 100% of Tier 1 suppliers audited each year.
- Contracts with Modern Slavery Clauses (%):
- Percentage of contracts that include explicit modern slavery prevention clauses.
- E.g., Target: 100% of supplier contracts to include these clauses.
- Certification of Suppliers (%):
- Percentage of suppliers certified to ethical standards, such as SEDEX or SA8000.
- E.g., Target: 90% of suppliers certified within a year.
2. Reporting and Transparency KPIs:
- Modern Slavery Statements Published:
- Annual publication of a modern slavery statement in compliance with legal requirements (e.g., UK Modern Slavery Act).
- E.g., Target: Publish by Q1 each year.
- Grievances Logged and Addressed (%):
- Percentage of reported modern slavery concerns investigated and resolved within a specified timeframe.
- E.g., 100% resolution within 30 days.
- Risk Assessments Conducted:
- Number or percentage of supply chain risk assessments conducted annually.
- E.g., 100 assessments completed in 12 months.
3. Training and Awareness KPIs:
- Employee Training Completion (%):
- Percentage of employees trained on modern slavery awareness and reporting procedures.
- E.g., Target: 100% of employees complete training annually.
- Supplier Training Participation (%):
- Percentage of suppliers trained on modern slavery risks and compliance requirements.
- E.g., Target: 85% supplier participation.
4. Supplier Engagement KPIs:
- High-Risk Suppliers Identified and Monitored (%):
- Percentage of high-risk suppliers identified and regularly monitored for compliance.
- E.g., Target: Monitor 100% of high-risk suppliers quarterly.
- Ethical Audits of Suppliers (%):
- Proportion of suppliers undergoing independent ethical audits.
- E.g., Target: 75% of all Tier 2 suppliers audited by the end of the year.
5. Candidate and Worker Protections:
- Grievance Mechanisms Available:
- Percentage of workers in the supply chain with access to anonymous grievance mechanisms.
- E.g., Target: 100% coverage for all workers.
- Worker Interviews Conducted:
- Number of direct worker interviews conducted during audits to assess working conditions.
- E.g., Target: 50 interviews per quarter.
- Fair Recruitment Practices Verified (%):
- Percentage of recruitment agencies verified for ethical hiring practices.
- E.g., Target: 100% verification of agencies used.
6. Corrective Actions and Accountability KPIs:
- Non-Compliance Incidents Resolved (%):
- Percentage of identified non-compliance issues (e.g., related to modern slavery) resolved within a set timeframe.
- E.g., Target: Resolve 90% of incidents within 60 days.
- Contract Terminations for Breaches (%):
- Percentage of contracts terminated due to modern slavery breaches.
- E.g., Monitor and maintain at < 1% annually.
7. Collaboration and Advocacy KPIs:
- Participation in Industry Initiatives:
- Number of partnerships or memberships in industry groups focused on eradicating modern slavery.
- E.g., Target: Join 2 new initiatives by year-end.
- Supplier Improvement Plans (%):
- Percentage of suppliers with action plans to address risks identified during audits.
- E.g., Target: 80% of high-risk suppliers have improvement plans in place.
8. Monitoring and Continuous Improvement KPIs:
- Risk Mapping Completion:
- Completion of a detailed risk map of supply chains and business operations.
- E.g., Target: Full mapping of Tier 1 and Tier 2 suppliers within six months.
- Reduction in High-Risk Suppliers (%):
- Year-on-year decrease in the proportion of high-risk suppliers.
I) POLICIES
1. Modern Slavery and Human Trafficking Policy
- Objective: Clearly state the organization's zero-tolerance stance on modern slavery and human trafficking in all operations and supply chains.
Key Inclusions:
- Definition of modern slavery and examples of prohibited practices.
- Commitment to identifying, preventing, and addressing modern slavery risks.
- Alignment with relevant legislation (e.g., UK Modern Slavery Act 2015).
- Responsibilities of employees, suppliers, and partners in upholding the policy.
2. Ethical Recruitment Policy
- Objective: Ensure that recruitment practices are fair, transparent, and free from coercion or exploitation.
Key Inclusions:
- Prohibition of recruitment fees charged to workers.
- Guidelines for verifying worker identity and preventing the retention of identification documents.
- Guidelines for verifying worker identity and preventing the retention of identification documents.
3. Supplier Code of Conduct
- Objective: Establish clear expectations for suppliers and contractors regarding modern slavery prevention.
Key Inclusions:
- Requirements for suppliers to comply with labor laws and ethical practices.
- Mandatory audits and due diligence processes for high-risk suppliers.
- Consequences for breaches, including contract termination.
4. Whistleblowing Policy
- Objective: Provide a confidential mechanism for employees, suppliers, and stakeholders to report concerns about modern slavery or unethical practices.
Key Inclusions:
- Clear instructions on how to report suspected violations.
- Assurance of protection against retaliation for whistle blowers.
- Commitment to investigate all reports thoroughly and take corrective action.
5. Grievance Mechanism Policy
- Objective: Enable affected individuals (e.g., workers) to voice grievances and seek remedies for exploitation.
Key Inclusions:
- Accessible channels for filing complaints (e.g., online portals, hotlines).
- Procedures for handling and resolving grievances fairly and promptly.
- Periodic review of grievance mechanisms to ensure effectiveness.
6. Risk Assessment and Due Diligence Policy
- Objective: Outline the procedures for identifying, assessing, and mitigating modern slavery risks in operations and supply chains.
Key Inclusions:
- Steps for conducting regular risk assessments.
- Focus on high-risk sectors, geographies, and supplier tiers.
- Requirement for suppliers to provide transparency and traceability in their supply chains.
7. Training and Awareness Policy
- Objective: Educate employees, suppliers, and stakeholders about modern slavery risks and their role in preventing it.
Key Inclusions:
- Mandatory training programs on modern slavery for all staff and supply chain partners.
- Continuous learning opportunities to stay updated on best practices and legal changes.
- Monitoring training completion rates and effectiveness.
8. Corporate Social Responsibility (CSR) Policy
- Objective: Demonstrate a commitment to ethical labor practices and human rights in broader business operations.
Key Inclusions:
- Pledge to support fair wages, safe working conditions, and workers' rights.
- Collaboration with non-profits, NGOs, and other organizations combating modern slavery.
- Investments in community initiatives that promote education and awareness.
9. Monitoring and Audit Policy
- Objective: Ensure regular and systematic monitoring of supply chains and business practices to detect modern slavery risks.
Key Inclusions:
- Independent third-party audits of suppliers and contractors.
- Continuous monitoring of compliance with anti-slavery policies.
- Use of data analytics to flag anomalies or potential risks in supply chains.
10. Recruitment Agency and Labor Provider Policy
- Objective: Prevent the use of unscrupulous recruitment agencies or labor providers that may exploit workers.
Key Inclusions:
- Requirement for recruitment agencies to undergo pre-qualification checks.
- Mandate to sign declarations of compliance with anti-modern slavery standards.
- Ongoing performance monitoring of agencies for ethical practices.
11. Reporting and Transparency Policy
- Objective: Ensure that the organization publicly reports its efforts and progress in combating modern slavery.
Key Inclusions:
- Publication of an annual Modern Slavery Statement.
- Disclosure of key actions, risk assessments, and mitigation strategies.
- Commitment to continuous improvement and transparency.
12. Non-Retaliation Policy
- Objective: Protect employees and workers from retaliation when raising concerns about modern slavery or unethical behavior.
Key Inclusions:
- Assurance that reporting parties will face no adverse consequences.
- Strict disciplinary actions against anyone who retaliates against whistleblowers.
- Clear communication of protection policies to all stakeholders.
13. Child Labor and Forced Labor Policy
- Objective: Explicitly prohibit child labor, forced labor, and any forms of bonded labor in operations and supply chains.
Key Inclusions:
- Minimum age requirements for workers in line with local laws.
- Verification mechanisms to ensure no forced or involuntary labor is employed.
- Remediation plans if violations are identified.
J) TRAINING
- The Organisation provides the following training to staff to effectively implement its stance on modern slavery. Key training programs include:
- Awareness Training: Educates staff on modern slavery forms, impacts, and compliance with laws like the UK Modern Slavery Act.
- Legal and Compliance Training: Covers anti-slavery laws, organizational policies, and consequences of non-compliance.
- Risk Identification Training: Helps identify red flags and high-risk sectors using assessment tools.
- Supplier Engagement Training: Guides procurement teams on due diligence, audits, and supplier compliance.
- Ethical Recruitment Training: Ensures fair hiring practices, banning fees and document retention.
- Whistleblowing Training: Trains staff on using confidential mechanisms to report concerns.
- Grievance Resolution Training: Prepares staff to handle and escalate exploitationrelated grievances.
- Legal and Compliance Training: Covers anti-slavery laws, organizational policies, and consequences of non-compliance.
- Leadership Training: Focuses on management accountability and integrating antislavery measures.
- Industry-Specific Training: Tailors content to high-risk practices in relevant sectors.
- Continuous Learning: Updates staff on new developments, legal changes, and case studies.
K) SLAVERY OFFICER
- The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the organization’s obligations in this regard.