Introduction

The UK Modern Slavery Act 2015 (the ‘Act’) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in their operations and supply chains. The Seetec Group is committed to developing its social and environmental responsibilities and is fully committed to playing its part in eradicating modern slavery. We advocate for transparency and collaboration to eliminate the risks of modern slavery and ensure that we take appropriate action where necessary.

The Seetec Group of companies is committed to operating and promoting ethical and lawful business practices within the workplace. This is evidenced through several certifications and accreditation, for example, our Investors in People (IIP) Gold accreditation, IIP Health and Wellbeing award, Inclusive Employers Standard accreditation, Certified B Corporation®, ISO45001 (Health and Safety Management), ISO 14001 (minimising environmental impact), and ISO27001 (information security). We are also a Disability Confident Leader and Real Living Wage employer.

This statement refers to the financial year ending 31^st March 2025 and relates to all businesses operating as part of the Seetec Group across the UK and Republic of Ireland during this time. It sets out the steps taken by Seetec to prevent modern slavery and human trafficking in our own operations and supply chains.

Our business areas and supply chains

Seetec Group is a Public and Business Services provider and operates across the UK and in the Republic of Ireland. During reporting period stated, the Group consisted of Seetec Business Technology Centre Ltd (including all its subsidiaries) and The Pluss Organisation Community Interest Company.

Seetec undertakes due diligence when considering taking on new suppliers and reviews the adherence of its existing suppliers to their policies on an annual basis. The organisation’s due diligence and reviews, include:

• Conducting supplier audits and/or assessments where general risks are identified.
• Where reviews identify any risks, taking steps to improve suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans to address any gaps
• Invoking contractual remedies against suppliers that fail to improve their performance in line with their contractual requirements and/or any agreed action plan, including the potential termination of the business relationship.

Responsibility, Risk Assessments and Policies

Responsibility and governance for the organisation’s Corporate Social Responsibility initiatives – which includes anti-slavery – sits with the Group Executive Board, and corporate risks are reviewed by the Audit, Risk and Assurance Committee. Risk analysis is carried out at all levels of the organisation’s governance structure and is monitored through the operational and strategic risk register management process.

The Cabinet Office Modern Slavery Assessment Tool and our own internal risk assessments show no part of our business or supply chain are at particular risk of modern slavery or human trafficking.

We continue to monitor risk through the policies, procedures and initiatives detailed.

Investigations and Due Diligence

Our approach to addressing modern slavery is supported by several organisational policies and we take any breach of our policies or allegations extremely seriously. In the last 12-months, there have been no reported incidents in relation to modern slavery or human trafficking.

We continue to ensure that due diligence is completed during the onboarding process of new supply chain partners, and annually thereafter. Once Due Diligence responses are confirmed as complete, they are collated and pass through Seetec’s governance processes, where a final risk analysis of the responses is conducted. Any partners assessed as falling outside of Seetec’s risk appetite will be prevented from moving ahead in the process. At this point, further liaison and discussion takes place with the partner to identify actions which will mitigate/control the impact of the risk within a set period. Seetec and the partner may agree that the completion of such actions forms part of the terms of partner contract as a result of this activity.

Policies

Modern Slavery Policy – sets out our commitment to preventing modern slavery or human trafficking in the delivery of our service and our full support in the promotion of ethical and lawful business practices within the workplace.

Whistleblowing policy – encourages all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.

Employee code of conduct – makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.

Our engagement process, Due Diligence, Contracts, and Supply Chain Management Framework – set out our commitment to ensuring that our supply chain adheres to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat their workers with dignity and respect, and act ethically and within the law at all times. The organisation works collaboratively with supply chain partners to ensure that they meet these standards and improve where required, however, serious violations of our code of conduct will lead to the termination of our business relationship.

Safer Recruitment and Vetting Policy and Procedures – specifies that we use only reputable employment agencies and always verify the practices of any new agency before accepting workers from that agency. All employees, contractors and agency workers have their right to work in the UK verified. As an organisation, we ensure that we adhere to legislation in relation to minimum age requirements, wages, and the Working Time Directive.

Safeguarding Policy – outlines our commitment to providing a safe environment for our workforce and customers and the routes to escalate issues. We also have nominated safeguarding leads across the whole organisation to provide support, and we operate a dedicated confidential Safeguarding phone line for external learners to report any causes for concern.

Training

We believe that awareness is one of our most effective methods to reduce the risk of modern slavery. Seetec requires all employees working within the organisation to complete training on our organisational policies. New employees complete our e-learning induction programme; this includes both a safeguarding module and a dedicated modern slavery module.  Our modern slavery training covers:

• our business’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, and the provision of products by an unrealistic deadline;
• 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 our organisation;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
• what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.

Performance Indicators

We have reviewed our key performance indicators. As a result, we require all colleagues to complete our modern slavery training module both upon joining the organisation, as part of the onboarding process, and annually thereafter.

In addition, we have reviewed and widened our due diligence checks, which now include additional questions which could support in identifying unethical or illegal conduct that may be linked to Modern Slavery;

• Has your organisation or any of its directors/partners, proprietors or senior managers ever been deemed, by a contracting authority, to be an excluded supplier or been placed on a debarment list?
• In the last three years, has your organisation had a complaint upheld following an investigation by the Equality and Human Rights Commission or its predecessors or a comparable body in any jurisdiction other than the UK), on grounds or alleged unlawful discrimination?

As a result of these changes, we score 80% on the Government’s Modern Slavery Assessment Tool and expect to reach 100% in the next financial year.

Raising Awareness

We continue to strengthen employee awareness of our stance on slavery and human trafficking through articles on our internal communications channels. Our Employee Assistance Programme also provides staff with a secure way of seeking advice about a range of topics, including modern slavery or human trafficking issues personally affecting them or their families.

Looking Ahead

Over the course of the next financial year, we will continue to raise awareness and understanding the risk of modern-day slavery within our business and enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking in relation to new and existing suppliers. Key performance indicators will be reviewed annually by the Group Executive Board to measure the effectiveness of actions, as well as identifying further opportunity to improve procedures.

This statement has been formally approved by the Seetec’s Group Executive Board and signed on their behalf.

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