DigiBlu Uk Limited Slavery and Human Trafficking Statement
DigiBlu UK Limited (“DigiBlu”) annual turnover exempts it from being required to comply with and report under the provisions of Section 54(1) of the Modern Slavery Act 2015. DigiBlu has voluntarily prepared this updated Statement to confirm the steps taken in its financial year ending 31 December 2019, which it is building upon during 2020, to ensure that slavery and human trafficking are not taking place directly within any part of our business or within our supply chain.
DigiBlu is a Company registered in England, delivering its services through its people who live and work in the United Kingdom and other jurisdictions in which the Company delivers services. DigiBlu is building in the work it undertook during 2019 to support the eradication of human trafficking and slavery throughout the world.
Key Areas of Focus Delivered in 2019 and Planned for 2020:
Producing a comprehensive Anti-Slavery and Human Trafficking Policy embedding procurement strategy processes in vigilant governance of supplier selection, procurement framework, risk assessment and contracting processes
Training employees directly involved in engaging suppliers on supplier sourcing, due diligence and contract management framework
Developing technology systems to improve visibility and management of the supply chain
Segmenting our supply base according to risk and criticality and applying suitable onboarding and contracting processes for each
Reviewing and enhancing prior year risk assessments.
Our Organisation and Business
DigiBlu is owned by its shareholders and provides its services in partnership with a small number of third-party technology products and services suppliers which comprise the DigiBlu supply chain. Our registered office is in Chelmsford, Essex, UK. All the people currently employed by and providing services to DigiBlu are based in the UK. Additional resources are, on occasion, provided by DigiBlu colleagues directly employed by a DigiBlu Group Company based in South Africa.
We operate through our leading brand DigiBlu and provide market-leading third-party products sourced from Blue Prism, Thoughtonomy, AntWorks, TrustPortal and SoftTools who comprise our main supply chain partners. We are committed to providing our customers 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.
We are committed to ensuring that 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.
Our Supply Chains
Our supply chains include robotic process automation (“RPA”) suppliers who in conjunction with DigiBlu provide public authority and private sector organisations with:
Cloud Hosting Services to help buyers deploy, manage and maintain software implementations by providing appropriate computer system processing, storage and network solutions;
Cloud Software which provides robotic process automation software to consistently deliver our clients’ business processes by the application of business rules and repetitive changes to their end customer’ data records; and
Cloud Support whereby we undertake business process analysis to develop, implement and maintain business process delivery through automated robotic process delivery systems.
Our Policies on Slavery and Human Trafficking
A key activity during 2020 is production of a DigiBlu Anti-Slavery and Human Trafficking Policy which will include guidance for our suppliers, UK Government guidance and fact sheets relating to this matter. We will confirm our zero-tolerance approach to modern slavery which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.
The Anti-Slavery and Human Trafficking Policy will encourage rigorous reviews by our suppliers of their own operations and those of their suppliers to ensure clear guidelines are in place to raise, in confidence, any identified wrongdoings which extends to slavery and human trafficking. All reports will be fully investigated, with appropriate remedial actions.
Assessment of Modern Slavery Risk within our Supply Chain
DigiBlu continues to focus its risk assessments on Modern Slavery reviews in higher-risk situations to determine where the risk of modern slavery and human trafficking lies both within DigiBlu and in its supply chain.
To help reduce our environmental impact, all DigiBlu employees are encouraged to work from home where practicable. When not practicable, such as when delivering face to face meetings and training with clients and suppliers then employees work either at its corporate offices in the UK and South Africa or at client or supplier premises. DigiBlu HR advisors engage with its employees to ensure the risks associated with modern slavery and human trafficking are understood.
Suppliers have been risk assessed according to the nature of services they provide and the geographical locations in which they operate. These assessments cover the entire scope of our business, our third-party suppliers and other professional service providers. Geographically, most suppliers are based in the UK, or we contract with and make payment to a UK office. We are aware from due diligence that some of our IT programming/coding suppliers, whilst having a UK office base with whom we have a contract, are part of global organisations and utilise the services of individuals based in countries with emerging economies. Our risk assessment has also highlighted the possibility that in service industries, particularly construction and cleaning, there is increased risk of workers being subjected to forced labour. We have categorised our suppliers as Tier1 (high risk), Tier 2 (medium risk) or Tier 3 (low) risk suppliers.
Due Diligence Processes for Slavery and Human Trafficking
DigiBlu understands that its biggest exposure to Modern Slavery remains with organisations, whilst having a UK office base, utilise services of individuals based in countries with emerging economies.
Existing suppliers categorised as Tier 1 High Risk Suppliers and Tier 2 Medium Risk Suppliers have been appraised of DigiBlu’s zero tolerance of modern slavery and have been asked to attest their compliance with the Modern Slavery Act 2015. DigiBlu has commenced the embedding of a robust procurement framework to support supplier onboarding and contract renewals. This includes, as part of our onboarding process, new suppliers in Tier 1 and Tier 2 being required to complete due diligence questionnaires incorporating questions on modern slavery and their associated policies and procedures. Review of responses will support new supplier due diligence so they can be made aware of DigiBlu’s zero tolerance and determination to avoid instances and risks of modern slavery.
Employees are required to complete refresher training covering DigiBlu’s statement on Modern Slavery and Human Trafficking Policy. New employee Induction training appraises them of the importance of this initiative.
Assessment of effectiveness in preventing modern slavery
To assess the effectiveness of DigiBlu’s Anti-Slavery and Human Trafficking Policy it will be reviewing:
investigations undertaken into reports of modern slavery (including any confidential concerns raised) and remedial actions taken in response; and
staff training levels.
The Board and all employees of DigiBlu are totally committed to do what they can to monitor and avoid the possibility of, directly or through third parties, becoming involved in the risks associated with instances of moderns slavery and or human trafficking.
This statement was approved by the Board of DigiBlu UK Limited
Chief Executive Office
DigiBlu UK Limited
Date 07 April 2020