Modern Slavery Policy

Introduction

PureCyber (“The Organisation”) is committed to the principles of the Modern Slavery Act 2015 and ensuring that all its business operations are free from involvement with slavery or human trafficking.

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.

The Organisation considers that modern slavery encompasses:

  • human trafficking

  • forced work, through mental or physical threat

  • being owned or controlled by an employer through mental or physical abuse or the threat of abuse

  • being dehumanised, treated as a commodity or being bought or sold as property

  • being physically constrained or to have restriction placed on freedom of movement

Commitment

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking.

 

Staff training

During induction, we ensure that staff fully understand the risks of modern slavery and human trafficking infiltrating our business and effectively operate our policies and procedures aimed at mitigating this risk.

Supply chains

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and onboarding procedure includes due diligence of the supplier's reputation, respect for the law, compliance with health, safety and environmental standards.

We haven't been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

We are committed to implementing and enforcing effective procedures and controls to minimise the risks of human trafficking and other modern slavery practices infiltrating our business operations or supply chains, [and acting ethically and with integrity in all our business activities and relationships].

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

 

Potential exposure

Due to the nature of our business, The Organisation considers itself to have a low risk of exposure to modern slavery in our business and supply chains.   

Steps

In accordance with the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:

  • reviewing your supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery

  • measures in place to identify and assess the potential risks in its supply chains

  • ensure staff involved in procurement activity follow the modern slavery procurement guidance on GOV.UK

  • creating action plans to address risk to modern slavery

  • any actions taken to embed a zero tolerance policy towards modern slavery

  • any training provided to staff on modern slavery.

This policy has been approved by Damon Rands, CEO, and will be reviewed every year.