What is your policy regarding Modern Slavery Act?

It is important that supply chains ensure compliance with the Moden Slavery Act, what is your policy in this regard?

Introduction

This Policy & Statement (“the Policy”) is made by Coeus Software Ltd, pursuant to the Modern Slavery Act (2015) (“the Act”).  We may refer to ourselves as 'Coeus', 'We', 'Our', or 'Us' for the purposes of this article.

1. Statement

1.1 Company Profile

  • Coeus is a leading developer and supplier of frontline digital mobility solutions which are deployed, with trust, into secure environments for:
    • Public Sector organisations (including Police Forces), or
    • Organisations typically operating in regulated markets/environments.
  • Coeus works with:
    • Suppliers which match key technical and environmental competencies where they assist in the delivery of products and services.
    • Carefully selected and competent Partners to assist our clients in the delivery of those products and services (which might occur at arm’s length), such as:
      • Delivery of professional services.
  • The Company is not involved in the construction industry but might supply its products and services to organisations operating within the construction industry.
  • The Company, or its Products and Services, are represented on a diverse range of procurement frameworks, which allow its clients to buy with confidence.

1.2 Our Commitment

  • Modern slavery is a crime and a violation of fundamental human rights. It can take many forms but have the common effect of the deprivation of liberty and exploitation for personal or commercial gain by a perpetrator upon those persons affected.
  • The Company fully supports the Government’s objectives to eradicate all forms of modern slavery and human trafficking.
  • Coeus has a zero-tolerance approach to modern slavery and commits to operate at the highest level of ethical standards and expects the same of its supply chain and partners.
  • We call upon all organisations to use their influence to eradicate the injustices of modern slavery and human trafficking.

1.3 Responsibilities

Responsibilities in regard this Policy are defined as:

  • Human Resources Director
    • Responsible for the maintenance of this Policy and Statement which shall be reviewed annually.
    • Ensuring business practices are compliant with the Act.
    • Managing and reporting upon suspected occurrences of non-compliance.
  • Management (all levels)
    • Promulgation of this Policy.
    • Referring reports and concerns made to them, to Human Resources.
  • All persons
    • Must comply with this Policy.
    • Refer concerns or provide feedback on the Policy to a Manager or Human Resources.
    • Follow the grievance process in the Employee’s Handbook if you have concerns that you feel are not being addressed.
    • Report concerns in accordance with the Company Whistleblowing Policy if necessary.

1.4 Reporting

If there is reasonable suspicion or evidence of non-compliance with the Modern Slavery Act, in connection with Coeus or any aspect of its supply chain, the Company encourages the reporting of those suspicions using the responsibility matrix.

Where responsibility lies for requesting advice, or reporting to the public authority, by individuals (within the Company), contact may be made to the Modern Slavery Helpline, either by:

Policy

Our commitment builds trust and serves to enhance and protect the integrity of the Company and our Clients. This will be achieved through:

  • Adopting a ‘zero tolerance’ approach to modern slavery, human trafficking, all forms of servitude and forced and compulsory labour.
  • Following Human Resources practices which comply with the Act and are transparent and auditable.
  • Adopting Supply Chain Management and Partner Management activities which are ethical, transparent, and unambiguous.
  • Permitting Continual Improvement, by providing mechanisms whereby this Policy and any associated policies and procedures may be reviewed and updated.
  • Providing mechanisms which allow all persons an opportunity to report suspected breaches of the Policy or non-compliance with the Act.
  • Performing reasonable due diligence in respect of Client organisations that will receive Coeus products and services.

Risk Management

  • Coeus will seek to adopt Risk Management in respect of its business dealings and compliance with the Modern Slavery Act such that:
    • This Policy continues to remain compliant,
    • Associated Policies and Procedures remain compliant, specifically that;
      • Acquisition and retention of Human Resources is reasonable and proportionate, and,
      • Engagement with Supply Chain and Partners is appropriate.
  • In respect of its business activities, Coeus considers that the potential risk of Modern Slavery arises from:
    • Procurement of goods and services for daily operational purposes from an unethical supply chain,
    • Partnering with organisations which themselves have an unethical supply chain or are themselves deemed to be non-compliant.
    • Supply of Products and Services to organisations which reasonably demonstrates a risk of non-compliance with the Act.
    • Acquiring and retaining Human Resources in an unethical or inequitable manner.
    • Suppression of suspected incidents of non-compliance with the Act, including where reasonable evidence exists.
  • In respect of its business activities, Coeus ensures risks are mitigated by:
    • Commitment to the maintenance and enforcement of this Policy,
    • Ensuring that the statements made in this Policy cover the scope of the risks identified,
    • Ensuring that associated policies and procedures (statements made therein) comply with this Policy and afford accountability and transparency,
    • Provision of training to Staff, where necessary.