BSR Software Ltd
Modern Slavery and Human Trafficking Statement 2022
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. BSR Software has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
BSR Software assesses whether particular supplier activities or countries are high risk in relation to modern slavery or human trafficking by;
Undertaking periodic reviews based around a suppliers’ country of operation and their category of supply, supported by the Global Slavery Index and news analysis and insights from labour and human rights groups.
If any high risk suppliers are identified and if any supplier is considered to be at risk in relation to possible slavery or human tracking, then BSR Software will either decline to trade with the supplier or will make further inquiries.
BSR Software operates the following policies for identifying and preventing slavery and human trafficking:
1. Code of Conduct encourages employees to do the right thing by stating the actions and behaviour expected of them when representing BSR Software and our customers.
2. Supplier contracts have been updated to make explicit reference to slavery and human trafficking.
3. BSR Software encourages all employees, customers and suppliers to report any concerns to management.
Supplier due diligence
BSR Software conducts due diligence when onboarding new suppliers, and on existing suppliers on a regular basis. Our zero-tolerance approach to modern slavery is communicated and agreed by all suppliers, contractors and business partners at the outset of our business relationship and reinforced as appropriate thereafter. We will terminate our relationship with suppliers and business partners breaching this policy.
Training & awareness
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us. Updates will be provided using established methods of communication between the business and BSR employees. All employees will be trained on our commitment in the fight against modern slavery including, how to identify red flags for potential cases of slavery or human trafficking and how to report suspicions of modern slavery.
BSR Software has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. BSR Software has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.
You must ensure that you read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.
You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company Director.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.
This Modern Slavery Act Disclosure Statement is subject to annual review and approval by BSR Software’s Board of Directors, in line with any changes in business practices or applicable law and regulations.