Introduction
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 May 2022.
Neo Technology Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.
Organisational structure
Neo Technology Limited has business operations in the United Kingdom as well as:
- India
We operate in the Technology sector. The nature of our supply chains is as follows: We work with a number of key direct contractors, who provide us with goods, such as outsourced business processes and IT software development services.
Policies
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.
These include the following:
- Recruitment and selection policy – We conduct checks on all prospective employees to verify that they are eligible to work in India and the UK.
- Supplier code of conduct – We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate.
- Staff code of conduct – We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
We make sure our suppliers are aware of our policies and adhere to the same standards.
Due diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:
- Internal supplier audits.
Our due diligence procedures aim to:
- Identify and action potential risks in our business and supply chains.
- Monitor potential risks in our business and supply chains
- Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
Risk and compliance
The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:
- Evaluating the slavery and human trafficking risks of each new supplier.
- Reviewing on a regular basis all aspects of the supply chain based on supply chain mapping.
We do not consider that we operate in a high-risk environment because The business operates in this risk level environment because the majority of our supply chain is based in India and in low-risk industries, such as software development and services. We also operate in a remote working environment which means contractors can work from home.
We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
Effectiveness
The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:
- We will train our staff about modern slavery issues and increase awareness within the Company.
- We will carry out a regular audit of suppliers – 100% of suppliers each year.
Training our staff
The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:
- How to identify the signs of slavery and human trafficking.
- What initial steps should be taken if slavery or human trafficking is suspected.
- How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
Next steps
In the next financial year, we intend to take the following steps to tackle slavery and human trafficking by:
- Introducing new policies and procedures and organising wider training for the internal team working on modern slavery and human trafficking issues.
The statement was approved by the board of directors.
Signed:
Vamsi Marupudi, Director Neo Technology Limited
Date:
20/07/2022