Modern Slavery Statement

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.

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.

Supply chains

In order to fulfil its activities, the main supply chains of the Organisation include those related to the supply of Technical staff, Managed services, Training and software support across the Telecoms industry. Flint’s main clients are but not limited to Cisco, Telefonica, BT/EE and Ericsson.

Potential exposure

In general, the Organisation considers its exposure to slavery/human trafficking to be very limited as we do not supply our services in a country where protection against breaches of human rights may be limited.

In the rare occasion where this may happen the Flint entity that covers this geography will take the necessary 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.

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 your supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery,
• any actions taken to embed a zero-tolerance policy towards modern slavery.

Policies

The Organisation has the following policy which further define its stance on modern slavery – Ethical Policy and Code of Conduct Policy pertaining to Human Rights and Modern Slavery.

Compliance Officer

The Organisation has a Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Approval

Date: 6th July 2022

Neil Burbidge
Flint Group CEO