Anti-slavery statement

The Modern Slavery Act 2015 (the Act) requires commercial supplying goods or services with a turnover of more than £36 million to prepare and publish an annual ‘Slavery and Human Trafficking Statement’. The statement must set out the steps an has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its business or supply chain.

Modern slavery is an international crime, affecting millions of people around the world and is an increasing global issue that transcends age, gender, and ethnicities. Sadly, vulnerable people from overseas as well as across the United Kingdom, are forced to work illegally against their will across many different sectors from agriculture, construction, hospitality, retail, manufacturing, and more.

Modern slavery in the UK can take many forms, including forced sexual exploitation, domestic slavery or forced labour on farms, in construction, shops, bars, nail bars, car washes or manufacturing.

EncompaaS EMEA Limited (EncompaaS) supports the Modern Slavery Act 2015 (the Act) and its provisions about slavery, servitude and forced or compulsory labour and about human trafficking, including provision for the protection of victims.

EncompaaS takes action to ensure that slavery and human trafficking are not taking place in our supply chains or in any part of our business.

In accordance with Section 54, Part 1 or 6 of the Modern Slavery Act 2015 (the Act), this statement sets out the actions that EncompaaS takes to ensure that slavery and human trafficking are not taking place in our supply chains, nor in any part of our business.

EncompaaS is a private limited company, incorporated in England and Wales. The Company directly employs professionally qualified people or external contractors who are employed under fixed term contracts for their professional services.

Our employee and business policies ensure fair treatment of our people regardless of their employment status. Our external suppliers are mostly UK- based companies in low-risk sectors such as professional services, technology, and software services.

EncompaaS has a zero-tolerance position on violations to the UK’s anti-human trafficking and anti modern slavery laws. The EncompaaS anti-modern slavery & human trafficking policy reflects the commitment to acting ethically and with integrity in all our employment and business relationships. Systems and controls are in place to ensure slavery and human trafficking is not taking place anywhere  in our supply chain. If we did identify breaches of these laws within our supply chain, we would support  companies in their efforts to ensure their compliance with the legislation. To date there have been NO instances of this occurring.

The EncompaaS Values of Drive What's Next, See It Succeed and Stronger United are the people pillars of our culture. They embody everything that we do at EncompaaS, and how we do business. They outline the expectations of our peoples’ behaviour with colleagues, customers, and suppliers.

The Value Stronger United sets the scene and states that “we don't lose sight of what's important – people. We care for our colleagues and customers.”

Our policies and procedures that are focused on supporting the Modern Slavery Act are enlivened by our culture and values.

Specific initiatives to address modern slavery risk include but are not limited to:

• An Anti-Modern Slavery & Human Trafficking Policy - which sets out the key issues and how to respond including a process for raising concerns internally.
• An annual Supplier Information Security Process – all suppliers to the Company must be vetted and approved to ensure that they meet all Company and security expectations.
• A Whistleblowing Policy, which aims to provide clarity on how EncompaaS provides support so that potential Whistle-blowers:
  • are encouraged to express concerns.
  • know how to express concerns.
  • know what will happen when concerns are expressed; and
  • feel safe in expressing concerns.

EncompaaS is committed to fostering a culture where potential Whistle-blowers feel safe and are encouraged to speak up if they observe or suspect conduct that concerns them.

• Employment policies that support and protect our people from unfair treatment and to promote a fair and inclusive workplace.
• Equal Employment Opportunity and Discrimination Policy - EncompaaS is an equal opportunity employer and is committed to ensuring that all applicants for selection or promotion are not  discriminated against on any of the grounds of discrimination contained in equal opportunity laws.

• EncompaaS has transparent and structured recruitment and selection processes both internally and externally focused that meet and exceed all relevant employment laws.

Our policies and procedures include due diligence on suppliers that we engage with, in accordance with our procurement policy. EncompaaS has a formally structured process in place to regularly review its existing suppliers and new suppliers to EncompaaS are required to meet our due diligence and  Information Security processes to ensure that the supplier has a good reputation with appropriate  practices in several areas, including security, people, and culture.

We may terminate our contract at any time should any instances of modern slavery come to light.

In our Terms of Service for EncompaaS all our Distributors are required to comply with all Modern Anti Slavery Obligations. Distributors must:

• comply with the Modern Slavery Acts to which it is subject;
• not engage in Forced Labour, Slavery, Servitude, Deceptive Recruiting for Labour or Services, Debt Bondage, Child Labour or Trafficking in Persons of any form;
• implement, maintain, and regularly review (throughout the term of this Agreement) systems,  policies and procedures designed to:
•  assess and manage risk associated with Forced Labour, Slavery, Servitude or Trafficking in  Persons in its own business and in its supply chain; and
• otherwise facilitate Distributor complying with the Modern Slavery Acts;
•  notify Customer promptly in writing if it becomes aware of any actual or reasonably suspected Forced Labour, Slavery, Servitude or Trafficking in Persons engaged in by Distributor or any entity in its supply chain in connection with this Agreement; and
• provide such information reasonably requested by Customer to enable it to comply with its reporting, risk management and other obligations imposed by the Modern Slavery Acts to which it is subject.

The EncompaaS EMEA management team are responsible for compliance within their respective teams and in their supplier relationships and to avail themselves of the Modern Slavery & Human Trafficking Statement and Policy.

All employees receive and participate in an Onboarding Program when they commence with the business where our policies, procedures and expectations are outlined.

EncompaaS conducts a review of the following items to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains

• right to work documentation and
• payroll audits.

EncompaaS logs complaints received via the whistleblowing procedure or through other sources and uses the following key performance indicators to measure how the steps we are taking are ensuring that slavery and/or human trafficking is not taking place within our business or supply chain

• No reports are received from our people
• No reports are received from the public
• No reports are received from our customers
• No reports are received from any law enforcement agencies .

As of the date of this Statement, EncompaaS has had no identified instances of modern slavery.

As of the date of this Statement, EncompaaS does not currently engage with any suppliers or procure any goods that present a known modern slavery risk in our supply chain.

This Modern Slavery & Human Trafficking Statement is subject to regular, ongoing management review and will be updated when required in accordance with the ACT or when significant changes to the business occur.