Modern slavery policy

Introduction

This statement sets out Neko Venture Partners Limited's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 06 April 2023 to 05 April 2024 As part of the IT security industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Neko Venture Partners Limited:
  • The organization undertakes professional IT security consultancy, software development and security research services. A proportion of these services are outsourced to individually approved consultants from third-party suppliers.
  • Consultants are individually interviewed in person as part of the onboarding process, and all reasonable efforts are made to confirm that they do not appear to be victims of modern slavery. Anti-modern slavery training is also a condition of their role and completion of regular refresher courses are required.
  • The outsourced consultants used and are presently either the owner/director of the organization and other individuals who are owners / persons with significant control of their own contracting companies, who the outsourcing contracts are with.

Countries of operation and supply

The organisation currently operates in the following countries:
  • United Kingdom

A major supplier is present in Vietnam and operates there. They have made an undertaking to abide by this policy and comply with it in all contracts conducted with Neko Venture Partners Limited and all other customers and suppliers.

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • Reading UN reports on slavery and referring to reports produced by modern slavery charities.
  • Following guidance in modern slavery training.

High-risk activities

The following activities are considered to be at high risk of slavery or human trafficking:
  • None identified at present.

Responsibility

Responsibility for the organisation's anti-slavery initiatives is as follows:
  • Policies: The directors of the company are responsible for putting in place and reviewing policies and the process by which they were developed.
  • Risk assessments: The directors of the company are responsible for conducting risk assessments which cover the potential for slavery and human trafficking.
  • Investigations/due diligence: The directors of the company are responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
  • Training: Modern slavery training is provided to directors, employees and subcontractors. Completion of it is a condition of their role.

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
  • Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can report them to the directors of the company.
  • Employee code of conduct The organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's supplier code of conduct will lead to the termination of the business relationship.
  • Recruitment/Agency workers policy The organisation does not currently use employment agencies to source labour, and has no plans to recruit further staff beyond the directors.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation's due diligence and reviews include:
  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through the organisation's own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • creating an annual risk profile for each supplier;
  • taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:
  • requiring all staff have completed training on modern slavery on onboarding and annually;
  • developing a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • reviews all existing suppliers on an annual basis

Training

The organisation requires all staff within the organisation to complete training on modern slavery as a condition of their employment. The organisation's modern slavery training covers :
  • our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline;
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and "Stronger together" initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation's supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by a series of emails to staff. The emails explain to staff:
  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available.

Board approval

This statement has been approved by the organisation's board of directors, who will review and update it annually.

Director's signature:

REDACTED FROM ELECTRONIC COPY

Director's name:

S. Walker

Date:

6th April 2024