Modern Slavery Statement

Introduction

Modern Slavery in all its forms of slavery and servitude, forced or compulsory labour and human trafficking is a heinous crime and we will not tolerate any such activities within our own operations or our supply chain. We are committed to stamping out modern slavery and are taking the appropriate steps to ensure that everyone who works for Castleton benefits from a working environment in which their fundamental human rights are respected and anyone that we do business with also upholds these principles.

This statement sets out Castleton’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.

Castleton Technology plc, 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

We are a market leader in software applications, business process outsourcing and technology solutions. We operate across the UK, Ireland, Australia, New Zealand and India and our supply chains are predominantly based within these countries.

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 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 minimum 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 48 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 Castleton Technology plc’s ‘Quality Management’ and ‘Environmental policy 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 our employees, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, Castleton Technology plc. 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 – Castleton Technology plc’s values of Right, Respect and Reliability makes clear to our employees the actions and behaviour expected of them when representing Castleton. 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 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 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
  • 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.

Awareness-Raising Programme

As well as training employees, the organisation has raised awareness of modern slavery issues by circulating information to employees.

The information explained to relevant employees:

  • The basic principles of the Modern Slavery Act 2015;
  • 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.

Modern Slavery Helpline

October 2019 marks two years since Unseen established the Modern Slavery Helpline, with support from founding partner BT and Salesforce.
Since opening it has received over 10,000 calls and online reports, working with the police, government, businesses, and the public to help people escape situations of exploitation.

 

March 2020 Promise

Castleton continue to mitigate the risk of slavery and human trafficking in our supply chain.

We will continue to review and increase our depth of work on modern slavery and ensure that we have put in place the most effective responses where risks have been identified. Our commitment to ensuring the prevention of slavery and human trafficking, either within our business or within our supply chain, is very clear. We will always treat people in our business and in our supply chain fairly.

We continue to ensure that the working conditions for all our employees continue to exceed the statutory requirements in all the countries that we operate in, and we conduct regular reviews against market standards.

We commit to continue to review our group policies annually and have already improved our whistleblowing policy in 2020, ensuring that there is an anonymous process for employees, customers and other business partners to report their concerns related to the direct activities, or the supply chains of Castleton Technology plc. Our whistleblowing procedure continues to be designed to make it easy for employees to make disclosures without fear of retaliation.

Over the next 12 months we will continue to strengthen our approach to managing the risk of modern day slavery within our business and supply chains

Due to the nature of the business, we have not identified any high-risk Modern Slavery concerns in 2019.

As an international business, Castleton recognises that modern slavery and human trafficking are significant global issues that present challenges for businesses around the world. In line with our values of Right, Respect and Reliability, we are committed to continually improving our practices to combat modern slavery and human trafficking within our supply chains. We have a zero-tolerance approach to these issues and act with integrity in all our business arrangements”

Dean Dickinson, CEO

 

Board Approval

This statement has been approved by the organisation’s board of directors, who will review and update it annually. Our Senior Management team take responsibility for implementing this statement and its objectives. They will ensure adequate resources and investment to ensure slavery and human trafficking isn’t taking place within our organisation or within our supply chains.