Our position on human rights within Velocitii Digital Solutions Ltd is clear and covered in our long-established Ethical Business Practices Policy and, more explicitly, in our Code of Conduct. We respect the human rights of all our employees and those within our supply chain and have zero tolerance of slavery and human trafficking.
We are committed to ensuring that slavery, trafficking, bonded labour, forced or servile marriage, descent-based slavery and domestic work and slavery does not take place in our business or any part of our supply chain by seeking to:
This Statement sets out the steps which Velocitii has taken to help ensure that slavery and human trafficking is not taking place in any part of our business or supply chains.
Velocitii Digital Solutions builds specialist teams that support government departments to deliver better, more efficient and value-for-money services through business change and digital transformation.
Our mission is to help government departments to improve public services, achieve better value-for-money and become ‘Digital by Default’.
All our businesses are dependent on our people and our supply chains to support the delivery of our services. Each business is responsible for ensuring that they can demonstrate compliance with the Modern Slavery Act by working to our Group policies and procedures.
As a company predominately offering specialist teams to our clients, our supply chain is characterised by skilled technical contractors and trades.
Occasionally we use suppliers for our operational requirements in certain areas. The materials we buy are in support of the services we deliver.
We have an established set of policies and procedures covering human rights in general and specifically addressing relevant areas to minimise the risk of slavery or human trafficking occurring in our businesses or supply chains.
Our relevant policies and procedures include:
Our Code of Conduct forms the cornerstone of our wider ethical business framework. It provides our people with the guidance and support necessary to carry out their work in the right way. We designed our code to help our people understand Velocitii Digital’s core values and the responsible behaviours which underpin them. It provides guidance and support for all Velocitii Digital personnel when undertaking their work and draws together all of our long-standing policies and procedures from all business areas into one simple and practical guide.
We demand the highest levels of ethical and moral stewardship in Velocitii Digital. We are committed to being a responsible business and to developing mutually beneficial and sustainable relationships with our stakeholders and business partners, based on trust and co-operation.
Over and above the requirements of the Modern Slavery Act, we endorse the tenets of the United Nations Global Compact Principles, the International Labour Organisation Declaration on Fundamental Principles and the Rights at Work and the Ethical Trading Initiative ‘Base Code’. We strive to ensure that employment is chosen freely; freedom of association is respected; working conditions are safe and hygienic; child labour is not used; wages are not lower than minimum wage; working hours are not excessive; no discrimination is practised; regular employment is provided; and no harsh or inhumane treatment is allowed.
We endeavour to carry out appropriate checks to ensure that any new applicant is suitable for the role that they have applied for. Prior to making an offer, it is our usual practice to ensure that all applicants are aware of what checks we will carry out. We make job offers subject to appropriate satisfactory vetting procedures (where required).
All our people undergo identity and Right to Work checks prior to commencing employment. We also carry out reference checking and, where applicable, DBS checks. We employ most of our people directly or on a fixed-term basis with checks in place to ensure that payment of salary is made direct to that person.
In addition to striving to ensure compliance with legislative requirements, we carry out additional background checks on a risk basis, either through our own assessment or one carried out in conjunction with our client.
Our Recruitment Procedure outlines the mandatory requirements we impose, which includes the requirement to use approved agencies in the recruitment process. Our On-Boarding Procedure seeks to ensure that third party providers can demonstrate that they comply with all legal requirements, including the requirement to comply with the Modern Slavery Act 2015.
Our Employee Handbook and Code of Conduct set out our policies and key procedures. We give all our people access to the Handbook and a summary version of our Code of Conduct when they begin working for Velocitii Digital.
These core documents, together with our targeted awareness on Modern Slavery and human trafficking helps us to deliver our key messaging so that our people can comply with our requirements.
We expect our suppliers and other business partners to have the same high standards as we impose on our own business. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain.
As part of our on-boarding process, our suppliers are required to read and acknowledge our Supplier Code of Conduct and our Supplier Guidance – Modern Slavery Act 2015 document. These documents set out key requirements for our suppliers including, amongst other things, the mitigation of risks associated with slavery and human trafficking. It is made available on our external website which makes our expectations clear, and improves the accessibility and transparency of our processes for suppliers.
Our Standard Terms and Conditions require our suppliers to comply with all legal requirements, including adherence to the Modern Slavery Act.
With the introduction of the Modern Slavery Act, we assessed our supply chain for potential areas of increased risk of non-compliance to the Act. We continue to do this and, where areas are identified, we carry out an audit, which will include a focus on compliance with employment as well as other regulatory and sustainability criteria. The defined criteria for assessing potential areas of risk within our supply chain are:
We enforce our policies and procedures in an effort to ensure that slavery and human trafficking is not taking place anywhere in our business or supply chain.
Our supplier on-boarding process includes standard due diligence procedures, which help us assess the suitability of a vendor to provide goods and services to Velocitii Digital against compliance to required standards. This process captures confirmation that they are committed to ensuring that slavery and human trafficking is not taking place within their own supply chain. Tender and supplier selection processes also include checks for acceptance of Velocitii Digital terms and conditions and the Supplier Code of Conduct.
Our procurement team carries out desktop audits as part of our supply chain management to provide assurance that our suppliers are responsible partners in our service delivery. We continue to analyse our supply chain for potential risk in the light of the changes that will come from the transformation projects within our business.
If the outcome of an assessment audit identifies any weaknesses in governance, we will seek to agree a detailed plan of action with the supplier to remedy the deficiencies. Failure by a supplier to respond to the questionnaire or to provide assurances that it has satisfactorily assessed its own risk of modern slavery, may lead us to review our business relationship.
We are using a number of key performance indicators (KPI’s) to measure how effective we have been in communicating awareness of our core policies and procedures related to the requirements of the Modern Slavery Act, and our other actions to seek to ensure that slavery and human trafficking is not taking place in any of our businesses or supply chains. The KPI’s used to measure against will be subject to ongoing review by the Board to ensure their continued effectiveness.
We continue to strengthen employee awareness of our stance on slavery and human trafficking. We are updating our guidance for our suppliers, adding details of plans for managing the risk within our supply chain. This complements the training created for our own people, so they understand the issues involved, become more aware of the risks, the signs to be vigilant of and how to raise awareness should they see or fear something suspicious.
We believe that improved awareness is one of our most effective methods to reduce the risk of modern slavery and with the help of both our employees and suppliers we aim to ensure that there are no opportunities to hide forced labour within our organisation or our supply chain.
To further spread awareness, we create articles and information briefings for all our personnel to complement the guidance provided to suppliers. We are taking a targeted approach to more detailed training on slavery and human trafficking (either by way of workshop training or an e-learning module, as appropriate). This will cover our people involved in our procurement processes and the hiring of staff, especially where this involves the promotion and monitoring or our agency workers.
We encourage our people, customers and suppliers to report any concerns about unlawful conduct that they suspect is taking place at work. This includes any concerns regarding the risk of slavery or human trafficking.
Our Whistleblowing Procedure provides our people and our business partners with the ability to report suspected wrongdoing. This service enables concerns to be reported without fear of retaliation in the knowledge that we do not tolerate harassment, victimisation or reprisals against anyone raising a concern in good faith.
In addition, employees who believe that they have come across an instance of modern slavery (or who may be a victim) and who need information and/or guidance on remedy, compensation and justice will be advised of their right to contact the Modern Slavery Helpline and/or other specialist support and assistance providers across the UK.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Velocitii Digital’s slavery and human trafficking statement approved by the Board of Directors.
This policy statement is reviewed on a regular basis to continue to make relevant sustainable commitments.
This policy has been approved and authorised by Michael Horrigan, Managing Director of Velocitii Digital on 1st April 2021.