Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slaver, 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.
Omnia is committed to ensuring transparency in our business and our approach to tackling modern slavery throughout our supply chains which is 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, and we expect that our suppliers will hold their suppliers to the same high standards.
As a provider of technology and associated services we operate across regulated markets in the private and public sectors, primarily our employees work across our operations in the UK and Europe only.
This policy has been published on behalf of Omnia (and applies to all group companies and subsidiaries).
The 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. This includes evaluating suppliers’ policies, procedures, and practices related to slavery and human trafficking.
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. Steps are taken to mitigate these risks, including implementing appropriate controls and monitoring mechanisms.
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, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery however ultimate responsibility for the implementation and compliance with this policy 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 to ensure that slavery and human trafficking are not taking place within our organisation or supply chains.
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. In support of this we provide training and capacity building programs to all relevant staff members to raise awareness of the risks of modern slavery and human trafficking and to ensure they understand their responsibilities in preventing and reporting such activities. Training is regularly updated to reflect changes in legislation and best practices.
The following company policies support us in ensuring that modern slavery is not taking place in our supply chains or business:
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.
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. It also details the due diligence and assessment conducted on all suppliers ensuring compliance to 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.
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 therefore 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.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage. If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.
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 manager or the compliance manager.
Omnia aim’s 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.
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.
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.
Omnia Smart Technologies will review and update this policy within six months of its financial year end and published on our web site in accordance with the requirements of the Modern Slavery Act 2015.
