Frameworks & Procurement

Modern Slavery & Human Trafficking Statement

Introduction  

This Statement is designed to satisfy the requirements of Part 6 Section 54 of the Modern Slavery Act (2015). Through Technology’s Processes, Procurement Policy and Procedures state our commitments to the highest standards of ethical conduct in all our activities, along with making continuous improvements in this area.  

 

Through Technology does not engage in, or condone, the practices of human trafficking, slavery or forced labour. As a value driven institution, our values underpin all that we do. We promote a culture internally and with other organisations where all individuals matter, where wellbeing is actively considered and where we are driven by our pursuit of social justice and the common good, and where people, the planet, and all living things are held in the highest regard.  

 

We are committed to improving our business practices to combat modern slavery and human trafficking and to ensure that we are not complicit in any human rights violations. We are committed to zero tolerance of slavery and human trafficking or child labour practices.  

Structure of Through Technology  

Through Technology is a registered limited company (company number 10675314).

Our supply chains  

 

Through Technology’s supply chains fall within the following categories:  

  • ICT Equipment and Cloud Services 

  • Professional Services 

 

Our business and supply chains which may pose risks in terms of slavery are in IT and AV equipment, where we only use large, established, and reputable businesses (such as Microsoft) who have their own Modern Slavery policies and statements. 

Our policies  

 

We are committed to making sure that there is no modern slavery or human trafficking in our supply chain or in any part of our business. We continue to develop our policies and procedures to reflect our commitment to acting sustainably, ethically and with integrity in all our business relationships.  

 

We are working to develop, implement and enforce effective procurement systems, processes, and controls to make sure child labour, slavery and human trafficking is not taking place within our supply chains. We expect all our suppliers to respect and treat employees in a morally and ethically appropriate manner. Our suppliers are expected to take steps and demonstrate a commitment to making sure that their own supply chain is free from child labour, modern slavery, and human trafficking. 

Through Technology has put in place several measures and policies to ensure compliance with the Modern Slavery Act 2015. We have developed Procurement Policy and Procedures that reflect our commitment to acting ethically and with integrity in all our business relationships and to implement and enforce systems and controls to ensure our values are instilled within our purchase to pay cycle. 

 

Our Company principles describe how the company’s values are embodied in the conduct of our business and makes explicit the requirement for ethical conduct by staff and students. The Company mitigates the risk of modern slavery occurring in its workforce by ensuring that directly employed staff are recruited by following robust HR recruitment policies. There is a whistleblowing policy in place for members of staff to raise any concerns about wrongdoing by the Company. Staff engaged on a temporary staff basis via agencies or as Associates (Contractors) are only engaged through established sources who can provide assurance that they comply fully with the requirements of legislation relating to the rights and welfare of their candidates and employees.  

Our Company does not currently make significant external investments, but we are working in 2022 to create an ethical investment policy against this eventuality. To this extent the Company does not knowingly invest directly or indirectly in organisations that breach human or animal rights or that are in breach of the Modern Slavery Act 2015.  

What we are doing to ensure compliance 

We are currently working on the following initiatives to ensure compliance with the Modern Slavery Act during 2022: 

  • Appointing a director as Modern Slavery Act (MSA) Lead for the business, with a responsibility to track any MSA related initiatives. 

  • Ensuring checks of Modern Slavery and Human Trafficking statements and policies are part of our procurement and partnership processes, to protect our supply chain. 

  • Creating an ethical investment policy. 

  • Ensuring this statement and other related policies are annually reviewed and amended, as necessary. 

  • Defining a preference for Fair Trade and equivalent standard products in our procurements. 

 

This statement and associated documentation will be reviewed annually and amended, as necessary. 

 

Peter Hanney 

CEO (Chief Executive Officer)