Introduction
Modern slavery is a real issue and affects people the world over depriving a person of their liberty and dignity for another person’s gain. It is a problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its own operations and its supply chain.
At PointWire, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking during the financial year 2020.
Our Business and Supply Chains
- PointWire Limited is a UK incorporated business with its registered office in Skegness, Lincolnshire
- We provide endpoint security solutions to organisations in the UK by supplying goods and services in this area by completing the work ourselves or by enlisting vendor partners
- We operate primarily in the UK but also work with customers and vendor partners on an international level.
We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.
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.
Risk Assessment
In the past year, we conducted a risk assessment of our supply chain by taking into account:
- The risk profile of individual countries based on the Global Slavery Index
- The business services rendered by the suppliers
- The presence of vulnerable demographic groups
- A news analysis and the insights of labour and human rights groups
This assessment will determine our response and the risk controls that we implement.
Policies
PointWire operates the following policies for identifying and preventing slavery and human trafficking in our operations:
- Whistleblowing Policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.
- Code of Conduct – our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
Supplier Due Diligence
PointWire conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:
- Assessing risks in the provision of particular services
- Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
- Requiring improvements to substandard employment practices
- Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
- They support all requirements under the 2015 Act
- They have a Modern Slavery Statement outlining their commitments, if applicable
- They ensure they adequately train their staff regarding their own responsibilities
- They provide awareness across their own organisations
- They have processes in place to ensure staff are treated in line with the act during the stages of recruitment and throughout employment.
Awareness
PointWire has raised awareness of modern slavery issues by providing information centrally that is focused specifically on modern slavery that is available to all our staff, which explains:
- Our commitment in the fight against modern slavery
- Red flags for potential cases of slavery or human trafficking
- How employees should report suspicions of modern slavery
Training
In addition to the awareness programme, PointWire has rolled out a learning pack to all employees, which covers:
- Various forms of modern slavery in which people can be held and exploited
- The size of the problem and the risk to our organisation
- How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
- How employees should respond if they suspect slavery or human trafficking
- How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
- What external help is available for the victims of slavery
- An attestation from employees that they will abide by the anti-slavery policy
Measuring how we’re performing
PointWire has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include:
- How many employees have completed mandatory training?
- How many suppliers have shared their own policies and commitments?
- How many suppliers have rolled out an awareness and training programme that is equivalent to ours?
This statement covers 1st November 2021 to 31st October 2022 and has been approved by the board of PointWire Limited.