UK Modern Slavery Act Transparency Statement 2020
Hilltop Digital Lab Ltd
This statement is made pursuant to Section 54, Part 6 of the U.K. Modern Slavery Act 2015 and sets out the steps the Company has taken to ensure that slavery and human trafficking are not taking place in its business.
The Company (Hilltop Digital Lab Ltd) (The Company), recognise its social responsibility in the communities in which it operates. As part of the Company’s Compliance & Ethics Program, the Company and its employees must adhere to a Code of Conduct. The Code of Conduct, and the various written policies that support it, are designed to create a culture of ethics and integrity and to facilitate compliance with the laws of all jurisdictions in which the Company operates.
A core tenet of the Company’s Code of Conduct is that the Company “will not tolerate behaviour that endangers” its business partners.
The Company opposes and prohibits the use of human trafficking, child labour, slavery and slave labour, and it expects the same from its business partners and suppliers. As a global business, the Company is committed to compliance with all applicable labour laws, including the U.K.’s Modern Slavery Act.
The Company Policy on “Combating Trafficking in Persons” requires all its employees, subcontractors, contractors and other business partners to comply with relevant labour laws and, where applicable, to the relevant provisions of the U.K. Modern Slavery Act.
The Company also conducts varying levels of due diligence on its business partners, depending on the potential risk presented by that relationship.
The Company’s Compliance & Ethics program provides relevant training and a number of venues through which its employees, contractors and business partners can report concerns regarding potential misconduct without fear of retaliation. The U.K. Modern Slavery Act is intended to address supply-chain issues and, although the Company does not generally rely on supply chains for the services it provides, the Company will work to ensure that it does not engage with partners that violate the spirit of such law.
When the Company enters into a U.K. government contract, whether as a prime contractor or subcontractor at any tier, it will provide notice of these provisions to all employees and contractors who will work on the contract, and designated employees and contractors will receive periodic training on these requirements.
The Company has implemented a standardised assessment process to gauge each vendor’s overall adherence to legal and contractual requirements. Assessing vendors on a more frequent and coordinated basis assists the Company in obtaining a more comprehensive understanding of the vendor’s position and approach to meet all regulatory, legal and business requirements:
The Company’s Vendor Oversight Team applies a risk based criteria of existing vendor oversight data, in the development, execution and launch of additional compliance oversight monitoring activities of vendors.
The Company’s Information Risk Management (IRM) Team is responsible for completing vendor risk assessments, when contemplating a new supplier relationship. This assessment is based on the information provided and risk the vendor poses to the organisation. Upon completion of this review, including monitoring questions, appropriate corrective actions are instituted and a closeout meeting is scheduled and findings shared with the appropriate vendor relationship owner (VRO).
The Company’s Vendor Management Office identify engagements with issues, track and trend findings, communicate to Executive Leadership, escalate for decision-making to the Hilltop Digital Lab Ltd Executive Risk Delegate (ERD) and support the overall communication process.
Vendor Risk Assessments/Vendor Management Plans are developed and implemented if required. A vendor is considered to have risk when certain criteria factors apply to an engagement with a vendor, which if present, will require completion of a Vendor Risk Assessment and Vendor Management Plan. The Vendor Risk Assessment / Vendor Management Plan process occurs upon vendor onboarding and on an annual basis and is completed by the VRO or business owner overseeing the vendor relationship (and administered by Enterprise Sourcing and Procurement (ES&P)).
Company Master Service Agreements incorporate specific terms and conditions in relation to Modern Slavery Act: “Slavery/Human Trafficking. Vendor represents and warrants that (i) to the best of its knowledge, it has not been and is not currently subject to any action, suit, proceeding, or claim formally commenced or pending, or any investigation with respect to slavery or human trafficking, including any actual or claimed violation of the Modern Slavery Act 2015 (the “Modern Slavery Act.”); and (ii) it has not and will not engage in any activity, practice or conduct that would constitute an offence under the Modern Slavery Act . Vendor shall implement due diligence procedures for its Vendors, agents, representatives, vendors or other third party resources (collectively, “Third Party Resources”) to ensure that such resources comply with the principles of the Modern Slavery Act.”
The Company businesses entering into a U.K. government contract will maintain procedures to prevent agents and Subcontractors at any tier and at any dollar value from engaging in trafficking in persons and to monitor, detect, and terminate any agents, subcontracts, or subcontractor employees that have engaged in such activities.
This Modern Slavery Act Transparency Statement 2020 has been reviewed and approved by Hilltop Digital Lab Ltd Board of Directors.