Introduction
This statement sets out Calvium’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2023.
As part of the technology sector, the Company recognises that it has a responsibility to take a robust approach to slavery and human trafficking.
The Company is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Company structure and supply chains
This statement covers the activities of Calvium:
Calvium is a creative digital agency combining expertise in research, software engineering, experience design and secure digital integration. We design and deliver bespoke business critical digital solutions and engaging digital placemaking experiences to fuel business growth.
Calvium consists of a core team of experts and trusted subcontractors. We do not depend on a supply chain to deliver our services. We support dispersed working and have an international team.
Countries of operation and supply
The Company currently operates in the following countries:
- United Kingdom
- Germany
Countries where we have contractors :
- Spain
- Portugal
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- The management team will assess any potential new client to ensure that the services we need to provide are not high risk in relation to slavery or human trafficking
- When hiring new staff the management team will review the home location of any new employee or sub-contractor to check that the country laws and regulations comply with the Modern Slavery Act
High-risk activities
The following activities are considered to be at high risk of slavery or human trafficking:
- The nature of Calviums’ business and the relationships we have with our partners and suppliers makes our exposure to slavery and human trafficking unlikely. Should any of these relations change or we seek to build business relationships in sectors that are of a higher risk, Calvium Limited will ensure to re-address this statement and make appropriate adjustments.
Responsibility
Responsibility for the Company’s anti-slavery initiatives is as follows:
- Policies: The Managing Director is responsible for putting in place and reviewing policies and the process by which they were developed.
- Investigations/due diligence: The ISO management team will be responsible for investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
- Training: A company-wide coffee meeting will be used to communicate and educate employees about the policy and how to be aware of the signs that an individual is a victim of slavery or human trafficking.
Relevant policies
The Company operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Whistleblowing policy: The Company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the Company. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Company’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can email the Managing Director in confidence.
- Employee code of conduct. The Company’s code makes clear to employees the actions and behaviour expected of them when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
Due diligence
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence and reviews include:
- Evaluating the modern slavery and human trafficking risks of each new supplier;
- Conducting supplier audits or assessments through Calvium’s ISO process, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
Performance indicators
The Company has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the Company is :
- making modern slavery training part of new employee onboarding
Training
The Company requires all staff within the Company to complete training on modern slavery.
The Company’s modern slavery training covers:
- How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- How to identify the signs of slavery and human trafficking;
- What initial steps should be taken if slavery or human trafficking is suspected;
- How to escalate potential slavery or human trafficking issues to the relevant parties within the Company;
Awareness-raising programme
As well as training staff, the Company has raised awareness of modern slavery issues by circulating an email to staff.
The email explains to staff:
- The basic principles of the Modern Slavery Act 2015;
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Company; and
- What external help is available, for example through the Modern Slavery Helpline.
Board approval:
This statement has been approved by the Company’s board of directors, who will review and update it annually.
Director’s signature: