Modern Slavery Policy

Last Updated: February 2024

1. Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial and calendar year 2024, which are concurrent.

DigiBlu UK Limited (“DigiBlu”) is exempt from complying with the Modern Slavery Act 2015 (the “Act”), however, the Company voluntarily complies with its provisions to ensure that we do not suffer or permit slavery and human trafficking either in our own operations of those of our supply chain. We assess and manage slavery and human trafficking risks through:

Organisation structure and supply chains
Policies in relation to slavery and human trafficking
Due diligence processes
Risk assessment and management
Key performance indicators to measure effectiveness of steps being taken
Training on modern slavery and trafficking.

We all have a duty to be alert to risks, however small and ensure management provides staff with a supportive reporting environment for all risks.

2. Organisation Structure and Supply Chains

DigiBlu is a company registered in England and Wales, delivering its services through its directly employed team of people and those of its third-party suppliers who live and work principally in the United Kingdom, USA, UAE, European and South African jurisdictions.

DigiBlu’s supply chain includes robotic process automation (“RPA”) and other technology suppliers who, in conjunction with DigiBlu, provide public authorities and private sector organisations with:

Cloud Hosting Services to help its clients deploy, manage and maintain software systems through appropriate computer system processing, storage and network solutions;
Cloud Software which provides robotic process automation software to consistently deliver DigiBlu clients’ business processes by the application of business rules and repetitive changes to their end clients’ data records; and
Cloud Support whereby DigiBlu undertakes business process analysis to design, develop, implement and maintain business process improvement delivery through automated robotic process delivery systems.

Digiblu is owned by its shareholders and provides its services in partnership with third-party technology products and services suppliers which comprise the DigiBlu supply chain. The Company’s registered office is in Chelmsford, UK.

DigiBlu operates through its own brand and utilises market leading third-party products sourced principally from Blue Prism, Thoughtonomy, AntWorks, TrustPortal, CLEVVA and SoftTools which comprise its main supply chain partners. DigiBlu is committed to providing its clients with the services, tools and products to support them in and enhance the provision of their end customer services delivery at lower cost and consistently higher quality through the automation of repetitive business processes.

3. Policies in Relation to Slavery and Human Trafficking

DigiBlu works with the appropriate UK Government fact sheets relating to this matter. DigiBlu confirms its zero-tolerance to modern slavery which reflects the Company’s commitment to acting ethically and with integrity in all its business relationships including enforcing effective systems and controls to ensure there is no slavery or human trafficking anywhere in its supply chain.

By working with the UK Government best practice DigiBlu is in a position to work internally and with our suppliers to ensure clear guidelines are in place to raise, in confidence, any identified wrongdoings which creates or risks creating instances of slavery and or human trafficking. All reports will be fully investigated, with appropriate remedial actions.

4. Due Diligence Process

Each organisation with whom DigiBlu has a relationship has a relationship manager, who owns and is accountable for ensuring that robust processes and procedures are in place to ensure avoidance of slavery and human trafficking. During each supplier review meeting, verification is sought to ensure the supplier has a systematic process to maintain vigilance against the risks associated with slavery and human trafficking in its own organisation and those of its suppliers.

DigiBlu remains totally committed to making its contribution wherever it can to help eradicate slavery and human trafficking throughout the world.

5. Risk Assessment and Management

DigiBlu undertakes risk assessment and management to prioritise scrutiny of those of its own and supplier locations which pose increased likelihood of slavery and or human trafficking. Increased frequency of engagement are undertaken at such locations.

6. Key Performance Indicators to Measure Effectiveness of Steps Being Taken

DigiBlu is currently working towards implementation of the following Key Performance Indicators (“KPIs”) to monitor its effectiveness to verify:

100% of new employees are appraised of the Statement
On each employment anniversary, employees are re-appraised of the Statement
During each supplier relationship meeting, compliance with the Statement is verified.

7. Training on Modern Slavery and Trafficking

Employees are required to complete initial induction and annual refresher training to reaffirm DigiBlu’s statement on Modern Slavery and Human Trafficking Policy. New employee Induction training appraises employees of the importance of this initiative. Employees are encouraged to be vigilant towards compliance in all environments and to escalate any concerns to their line manager. If no action is taken then the Company’s Whistleblowing Policy should be used as further escalation.

8. DigiBlu’s Commitment

The Board and all DigiBlu employees are totally committed to ensuring that in its own organisation and those of its supply chain there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Modern Slavery Act 2015.

This statement was approved by the Board of DigiBlu UK Limited.

Signed

Vic Gysin

CEO, DigiBlu UK Limited

29 January 2024