Modern Slavery Policy
4C Strategies Limited

Document ref.:            Modern Slavery Policy            
Version:                      1.0                                                                                                      
Originator:                 JC                                                                                                                   
Date:                          January 2025   

A) ORGANISATION

This statement applies to 4C Strategies Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to 4C Strategies’ financial year October 2023 to September 2024.

B) ORGANISATIONAL STRUCTURE

4C Strategies is a leading independent IT infrastructure consultancy, who develop strategy, define requirements, assist with procurement and deliver all types of ICT projects.  The Organisation has worked for a range of private and public sector organisations to devise and deliver innovative and best value IT infrastructure projects to meet their business requirements.

4C Strategies is based in a single office at Harborough Innovation Centre, Airfield Business Park, Leicester Road, Market Harborough LE16 7WB.  The labour supplied to the Organisation in pursuance of its operation is carried out in all regions of the United Kingdom.

C) DEFINITIONS

The Organisation considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

The Organisationacknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, and in many cases exceeds those minimums in relation to its employees.

E) POTENTIAL EXPOSURE

The Organisation considers its risk of exposure to modern slavery to be low. It has, however, taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

In the operation of its business, the Organisation’s main supply chains are those related to the provision of services. The Organisation considers its main, albeit low, exposure to the risk of slavery and human trafficking to exist in its supply chains.

F) STEPS

The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.  In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place.  These steps include:

• Supplier Due Diligence: Conduct checks on all suppliers to ensure they adhere to ethical labour practices.

• Supplier Contracts: Include clauses in contracts that require suppliers to comply with the Modern Slavery Act 2015.  

• Training and Awareness: Provide modern slavery training for relevant employees  helping them to recognise / report signs of forced labour or human trafficking.

• Reporting Mechanisms: Establish clear reporting mechanisms for employees to report any concerns related to modern slavery.

G) POLICIES

The Organisation is working to integrate modern slavery policies into its ISO 9001 framework, including:

• Supplier Evaluation: Ensuring suppliers adhere to ethical labour practices and conducting due diligence.

• Risk Management: Identifying and mitigating risks related to modern slavery within the supply chain.

• Training and Awareness: Educating employees and suppliers about modern slavery and how to prevent it.

• Continuous Improvement: Regularly reviewing and improving policies and procedures to address modern slavery risks.

H) TRAINING

TheOrganisation provides the following training to staff to effectively implement its stance on modern slavery

• Digital Induction: Upon commencement of employment, all employees undergo a structured digital induction process. All employees are made aware of The Group policies relating to standards of behaviour that it requires from them.

• Awareness: Training on awareness of modern slavery to those within the Organisation who have been identified as having responsibilities in this regard.

I) SLAVERY COMPLIANCE OFFICER

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations in this regard. 

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval:   20 / 01 / 2025

Name:                        Gill Rowbotham, Director