Anti Slavery and Human Trafficking Policy

Introduction

Northway Communications Services (UK) Ltd are committed to eliminating acts of modern-day slavery and human trafficking within our businesses and from within our supply chains.

As an organisation with an annual turnover of less than £36 million pounds it is not a requirement that we publish a human trafficking statement. However, as an organisation we see the upmost importance in following the guidelines as means to ensure that modern slavery does not exist within our business or supply chain.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and is our slavery and human trafficking statement for the financial year ending 31 March 2022.

Organisational structure, business and supply chains

Northway Communications Services (UK) Ltd is a trading company in England Wales as recognised by Companies House. We are a supplier of IT telecommunications and network services with offices solely in the UK. Services provided to our customers are both from our own intellectual properly or where we are recognised partners or resellers from other organisations.

Policy on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains. This policy 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 is not taking place anywhere within our supply chains.

Due diligence

We consider ourselves to be a ‘low risk’ business with regard to slavery and human trafficking. However, we foster a culture that encourages the identification and reporting of any such risks within our business. We recruit all our employees either

Assessing and managing risk

We have a whistle-blowing policy in place and, as part of our efforts to identify and mitigate risks within our supply chain, we are introducing systems to identify, assess and monitor potential risk areas.

Effectiveness in combating slavery and human trafficking

We have zero tolerance to slavery and human trafficking. To ensure that all those in our supply chains comply with our values we are putting in place a supply chain compliance programme that will require our suppliers to confirm that they have a slavery and human trafficking policy in place and that they require the same from their suppliers.

Training

We are providing appropriate training to ensure that relevant employees understand the risks of modern slavery and human trafficking within our business and supply chains.