Slavery and Human Trafficking Statement

At Exponential-e we are committed to improving our practices to combat slavery and human trafficking. We oppose slavery and human trafficking in all its forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our business or in our supply chains.

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our supply chain comprises of suppliers who provide a range of products and services necessary for our business operations and critical to the provision of our services to our customers. These include providers of outsourced professional services, recruitment services, telecommunications engineering installation services, IT hardware products, and providers of mobile IT infrastructure services.

Our Anti-slavery and human trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. Due diligence and risk assessment. To help identify and monitor the risk of slavery and human trafficking in our supply chains are subject to due diligence and risk assessment we do the following: (a) We require our suppliers to enter into contractual obligations that include the right of audit by us. (b) Our onboarding process applies controls such as requiring suppliers who contract on our standard terms to certify annually that they comply with the Modern Slavery Act 2015 (“Modern Slavery Act”) and our antislavery and human trafficking policy. These are in line with our business ethos and help us to continue to fulfil our commitment to eleven international standards (six of which are ISO).

Our plans for the future with respect to our supply chain

  1. We ensure our suppliers are aware that a copy of our Slavery and Human Trafficking Statement is available on request and also accessible via our website.

  2. We will regularly reinforce to our suppliers, our expectation of the same level of commitment and high standards in tackling modern slavery in their own supply chain.

  3. We will review evidence of our suppliers’ commitment to tackling modern slavery and expect all our suppliers to hold their subcontractors to the same high standards.

  4. We will carry out additional vetting of our tier 1 suppliers for compliance with key supply chain legislation (including the Modern Slavery Act) using the supply chain management software, Risk Ledger.

  5. We will continue to review our supplier onboarding process to ensure our supply chain reflects our commitment to combatting modern slavery and human trafficking by:

    1. vetting our suppliers / sub-contractors for ethical labour practices;
    2. keeping a record of the types of issues identified on screening suppliers/ subcontractors;
    3. maintaining the split of our suppliers in tiers by risk level (high, medium and low) which helps us to identify the tier of suppliers we have vetted each year; and
    4. placing on hold our dealings with suppliers who we have identified as not compliant with our modern slavery requirements until such time as we are satisfied that such suppliers comply with our requirements.

We ensure that only those who choose to work freely are employed within our business. Each individual’s human rights are important to us; we do not condone any form of discrimination, harassment or bullying. We recognise that where workers are employed through business partners or recruitment agencies, we are not directly responsible for the employee relationship or how they manage their employees. To mitigate the risk, we consider the recruitment agents Exponential-e Limited Slavery and Human Trafficking Statement as part of our supply chain which means that they are subject to due diligence and risk assessment like any other supplier. For our employees, we provide them with an opportunity to raise any concerns or complaints.

Our employees have access to the Whistle blowing Policy. Effectiveness in combating slavery and human trafficking We have zero tolerance to modern slavery and human trafficking. To ensure that all those in our supply chain comply with our values we monitor and enforce compliance with those values in line with our plans for 2023 set out above. Training / Creating Awareness To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, training is provided to relevant employees via our learning management system. One of the ways we evaluate our progress is by encouraging our employees in procurement roles to receive accreditation from the Chartered Institute of Procurement and Supply.

The employees receive training on ethical purchasing. From that training, employees gain a better understanding on the nature of any risks we may face as an organisation and assist the business in implementing supportive actions where necessary. Using the supply chain management software, Risk Ledger, we require our tier 1 suppliers to provide evidence of training their employees and meeting key performance indicators with respect to Modern Slavery Act. Exponential-e will continue to monitor its supply chain and will reassess this statement annually to ensure that it is continuing to meet its organisational values. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

We recognise that where workers are employed through business partners or recruitment agencies, we are not directly responsible for the employee relationship or how they manage their employee. To mitigate the risk, we consider the recruitment agents as part of our supply chain which means that they are subject to due diligence and risk assessment like any other supplier.

For our employees, we provide them with an opportunity to raise any concerns or complaints. Our employees have access to the Whistle blowing Policy.

Training / Creating Awareness

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our employees through our induction programmes, face to face training with their Manager and a variety of courses on our internal training portal, Edison. One of the ways we evaluate our progress is by requiring our employees in procurement roles to receive accreditation from the Chartered Institute of Procurement and Supply (CIPS).

The employees receive training on ethical purchasing. From that training, employees gain a better understanding on the nature of any risks we may face as an organisation and assist the business in implementing supportive actions where necessary.

In relation to suppliers, we have included in our standard supplier agreement a requirement that our suppliers comply with the Modern Slavery Act 2015 and our policy on anti-slavery and human trafficking.

We also ask our suppliers to certify annually that they continue to comply with the Modern Slavery Act 2015 and our applicable policy.

Exponential-e will continue to monitor its supply chain and will reassess policies annually to ensure that it is continuing to meet its organisational values.