Modern Slavery Policy

Modern Slavery Policy

Policy Statement

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. Omnia Smart Technologies Limited (Omnia) 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 business or in any of our supply chains.

Supply Chain

Omnia is committed to ensuring transparency in our business and our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015 (the Act). We expect the same high standards from our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.

As a provider of technology and associated services we operate across regulated markets in the private and public sectors, primarily with employees working across our operations in the UK and Europe only. This policy applies to all persons working on behalf of Omnia or one of its subsidiaries 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.

All goods and services procured go through a central team, which is responsible for assessing the suitability and any associated risk of suppliers and ensuring the relevant due diligence checks are conducted. We conduct due diligence assessments on all potential suppliers and regularly review existing suppliers to ensure compliance with our anti-slavery and human trafficking policies.

We identify and assess the risk of slavery and human trafficking in our business and supply chains. This includes evaluating geographical locations, industries, and specific suppliers where there may be a higher risk, and taking steps to mitigate these risks.

Responsibility for the Policy

The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The compliance team have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, and auditing internal control systems and procedures. Ultimate responsibility for implementation and compliance firmly remains with the CEO and Board of Directors.

We measure the effectiveness of our efforts to prevent slavery and human trafficking through various performance indicators, including compliance audits, supplier assessments, and incident reporting mechanisms. We are committed to continuously improving our practices.

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. We provide training and capacity building programs to all relevant staff members to raise awareness of the risks of modern slavery and human trafficking.

Our Policies in Relation to Modern Slavery

The following company policies support us in ensuring that modern slavery is not taking place in our supply chains or business:

Equal Opportunities and Diversity Policy

Ensures appropriate procedures are in place to prevent any breaches to international human rights standards, including the United Nations' Universal Declaration of Human Rights (UDHR), the International Labour Organisation (ILO) core conventions on Labour Rights, and the Act.

Ethical Purchasing Policy

Sets out our strategic approach and the key principles and priorities that apply to all procurement activities, ensuring we have control over our supply chain and potential risks. The policy is complemented by our Ethical Code which sets out our expectations of suppliers in terms of ethical procurement, human rights and governance, including due diligence and assessment conducted on all suppliers ensuring compliance with relevant legislation.

These policies apply across the organisation and are available to all employees via our intranet site and website. The policies are managed by relevant functional heads; our company-wide risk management framework and reporting processes support the escalation of policy issues and the effective management of issues where identified in our business.

Compliance with the Policy

Employees must ensure they 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 manager, compliance team or the CEO as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. If you believe or suspect a breach of this policy has occurred, you must report it in accordance with our Whistleblowing Policy as soon as possible.

Omnia aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy. 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.

Communication and 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, and regular training will be provided as necessary.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Updating this Policy

Omnia Smart Technologies will review and update this policy within six months of its financial year end and publish it on our website in accordance with the requirements of the Modern Slavery Act 2015.