Modern Slavery Statement

Introduction

This statement sets out Zeela Consulting Ltd’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

Zeela Consulting Ltd, including its associated and subsidiary companies, recognises that it has a responsibility under the Modern Slavery Act 2015 to take a robust approach to slavery and human trafficking and we are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking.

Organisational Structure and Supply Chains

Due the nature of our services, our business operations are predominantly in the Software Development and Technical arena, in addition to professional services including project management, customer support, service delivery and implementation.

We provide services to a range of private and public sector organisations, such as local and national government.

Our supply chain primarily consists of Independent Contractors as and when required.

Relevant Policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

HR Policy - We promote our Modern Slavery Policy within our Team Handbook which is available to all colleagues and is provided upon commencement of employment. We have zero tolerance of any threat of physical or sexual violence, harassment or intimidation against employees and their family, or close associates. Our policies are clearly defined and communicated to all employees. All our employees are treated fairly and equally, and are paid at least the national living wage. Our employees won’t be forced to work in excess of the number of hours permitted in law, and normal working hours won’t exceed 35 hours per week average unless the employee agrees.

Purchasing Policy - The organisation is committed to conducting purchasing activities in a fair, objective and transparent manner that satisfies the requirements of accountability and internal controls including but not limited to Zeela Consulting Ltd’s ‘Quality Management’, ‘Environmental’, ‘Ethical Code of practice’, ‘Anti-Bribery’ and ‘Modern slavery and Human Trafficking’ policies which fulfil legal and financial obligations and effectively manages commercial risk. Emphasis is placed on selecting suppliers and service providers that demonstrate recognisable environmental, sustainable, business integrity along with Corporate Social Responsible (CSR) standards including but not limited to compliance with laws and regulations, respect for human rights, labour working conditions, equal opportunities, health and safety accreditation, maintenance and promotion of information security, fair trade and acceptable corporate ethics.

Recruitment Policy - The organisation uses only specified, reputable employment agencies to source agency workers and always verifies the practices of any new agency it is using before accepting workers from that agency.

Whistleblowing Policy - We encourage all of our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Zeela Consulting Ltd. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

Our values - Zeela Consulting Ltd’s values of Knowledge, Integrity and Action makes clear to our employees the actions and behaviour expected of them when representing Zeela Consulting Ltd. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.

Due Diligence

We undertake due diligence in relation to slavery and human trafficking when considering taking on new suppliers, and review our existing suppliers on a periodic basis. Our due diligence and reviews include:

Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking

Evaluating the modern slavery and human trafficking risks of each new supplier

Conducting supplier audits or assessments which have a greater degree of focus on slavery and human trafficking where general risks are identified

When a supplier is deemed to be higher risk by country of origin and/or lack of suitable policy/processes, an investigation is raised and assessed by senior members of the purchasing team which can result in the vendor being inactivated.

Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship

Action taken to address Modern Slavery

Countries and regions are assessed for risk based on the Global Slavery Index, taking into consideration the latest updates from The Department for International Trade.

Awareness-Raising Programme

The organisation has raised awareness of modern slavery issues by circulating information to employees.

The information explained to relevant employees:

The principles of the Modern Slavery Act 2015 and how it applies to Zeela Consulting Ltd;
How employers can identify and prevent slavery and human trafficking;
What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
What external help is available, for example through the Modern Slavery Helpline.

We are currently improving our colleague mandatory training and planning to strengthen knowledge through these activities.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Zeela Consulting Ltd’s slavery and human trafficking statement.