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Modern Slavery Policy

Introduction 

This statement sets out Calvium’s actions to understand all potentialmodern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is noslaveryor human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2022. 

As part of the technology sector, the Company recognises that it has a responsibility to take a robust approach toslaveryand human trafficking. 

The Company is absolutely committed to preventingslaveryand human trafficking in its corporate activities, and to ensuring that its supply chains are free fromslaveryand 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 slaveryor 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 toslaveryor 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 ofslaveryor 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-slaveryinitiatives 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 ofslaveryand 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 ofmodern slaveryrisks and steps to be taken to preventslaveryand 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 slaveryor 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 themodern slaveryand human trafficking risks of each new supplier; 
  • Conducting supplier audits or assessments through Calvium’s ISO process, which have a greater degree of focus onslaveryand human trafficking where general risks are identified; 

 

Performance indicators 

The Company has reviewed its key performance indicators (KPIs) in light of the introduction of theModern SlaveryAct 2015. As a result, the Company is : 

  • requiring all staff to have completed training onmodern slaveryby March 2022; 

 

Training 

The Company requires all staff within the Company to complete training onmodern slavery.

The Company’smodern slaverytraining covers: 

  • How to assess the risk ofslaveryand human trafficking in relation to various aspects of the business, including resources and support available; 
  • How to identify the signs ofslaveryand human trafficking; 
  • What initial steps should be taken ifslaveryor human trafficking is suspected; 
  • How to escalate potentialslaveryor human trafficking issues to the relevant parties within the Company; 

 

Awareness-raising programme 

As well as training staff, the Company has raised awareness ofmodern slaveryissues by circulating an email to staff. 

The email explains to staff: 

  • The basic principles of theModern SlaveryAct 2015; 
  • How employers can identify and preventslaveryand human trafficking; 
  • What employees can do to flag up potentialslaveryor human trafficking issues to the relevant parties within the Company; and 
  • What external help is available, for example through theModern SlaveryHelpline. 

 

Board approval:

This statement has been approved by the Company’s board of directors, who will review and update it annually. 

 

Director’s signature:

signature
21 January 2022