Modern Slavery Statement
This statement applies to all companies within and associated to the Biconic Group (referred to in this statement as ‘The Group’: Compu b Limited, NuConnect Limited, Jukugear and Blink 24) and sets out the Group’s actions to understand all potential slavery risks related to its businesses and to put in place steps that are aimed at ensuring that there is no modern slavery or human trafficking in its own businesses and its supply chains. The information included in the statement refers to the financial year 2018.
B) ORGANISATIONAL STRUCTURE
The Group has business locations in London and the greater London area, Milton Keynes and a number of business premises across the Republic of Ireland and is controlled by an advisory board and the CEO of the group.
The main activities of the group are the sale of high technology products and accessories. The goods are sold in stores, on-line and to other business customers and companies, educational establishments and the public sector. Demand for our products is consistently high throughout the year and is therefore not seasonal.
The labour supplied to the Group in pursuance of its operation is carried out in the UK and the Republic of Ireland.
The Group considers that modern slavery encompasses:
Forced work, through mental or physical threat;
Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
Being dehumanised, treated as a commodity or being bought or sold as property;
Being physically constrained or to have restriction placed on freedom of movement.
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Group does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and Republic of Ireland and in many cases exceeds these.
E) SUPPLY CHAINS
In order to fulfil its activities, the Group’s main supply chains include those related to supply of high end technological products and accessories from various suppliers in the UK, USA, EU and China. We understand that the Group’s first tier suppliers are intermediary traders and therefore have further contractual relationships with lower tier suppliers.
F) POTENTIAL EXPOSURE
The Group considers its main exposure to the risk of slavery and human trafficking to exist in its technology and accessory supply chains because they involve the provision of labour in a country where protection against breaches of human rights may be limited.
In general, the Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Group is taking the following steps to ensure that modern slavery is not taking place:
Employee Code of Conduct
This code of conduct makes it clear to employees the actions and behaviours expected of them when representing the Group. The Group strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
We have a robust recruitment policy which includes “eligibility to work in Ireland, UK and EU” checks to safeguard against human trafficking or individuals being forced to work against their will.
We are in the process of reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected of being, involved in modern slavery. The deadline for completion of this is July 2018.
In 2018 the Group will be introducing new measures to assess and manage the risk across our supply chain.
H) KEY PERFORMANCE INDICATORS
The Group will set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Group or its supply chains.
Regular site visits to suppliers
Completion of questionnaires by suppliers
We aim to have this in place by September 2018.
The Group has the following policies which further define its stance on modern slavery (see point G above):
Employee Code of Conduct
The Group provides the following training to staff to effectively implement its stance on Modern Slavery:
All our policies (code of conduct, Modern Slavery Statement) are currently made available to all staff through the Employee Handbook and Schoology (our on-line portal for learning and development). We will be providing more education to further inform and educate our employees about Modern Slavery and Human Trafficking in 2018. This will be an on-going process.
K) COMPLIANCE OFFICER
The Group has a People Operations Manager, to whom all concerns regarding
modern slavery/human trafficking should be addressed, and who will then undertake relevant action with regard to the Group’s obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
L) BOARD APPROVAL
This statement has been approved by the Group’s advisory Board and its CEO on 03/05/2018 and will be reviewed and updated on an annual basis.
Ciaran McCormack, CEO, B.ICONIC Group