Anti-Slavery Statement

Introduction

We are committed to the highest standards of ethical conduct and integrity in our business activities in the UK and overseas. We acknowledge our responsibilities under the Modern Slavery Act 2015, are committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our supply chains are free from slavery and human trafficking. We understand that this requires an ongoing review of our internal practices in relation to employees, agents or consultants or any person or body acting on our behalf, and our supply chains.

Organisational structure and supply chains

1. This statement covers all Hublsoft activities, primarily software development and delivery into European and US markets.
2. Hublsoft considers its exposure to modern slavery to be limited. Nonetheless, it has 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.
3. In the operation of its business, Hublsoft’s main supply chains are those related to the provision of services. Suppliers are predominantly operating to deliver technical software, hardware and infrastructure requirements, and other professional support services. Hublsoft considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains.

Commitments

1. Hublsoft has a zero-tolerance policy towards modern slavery. It will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
2. The labour supplied to Hublsoft in pursuance of the services it provides is carried out wholly in the countries where those services are provided i.e. United Kingdom.
3. No labour provided to Hublsoft in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Hublsoft 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.
4. Hublsoft offers employment contracts on a guaranteed hours basis only; no offers of employment are made on a zero hours basis.
5. Part-time and fixed-term employees within Hublsoft are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, Hublsoft is able to rely on objectively justifiable grounds.
6. Hublsoft employees are offered a competitive remuneration package and Hublsoft prides itself on the additional benefits it is able to offer its employees on a wide variety of platforms. It conducts staff surveys on an anonymous basis to give employees a voice on their individual employment, their department and Hublsoft as appropriate.

Hublsoft considers that modern slavery encompasses;

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

Responsibility

Hublsoft carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains.

Hublsoft has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.

In accordance with section 54(4) of the Modern Slavery Act 2015, Hublsofthas contacted (or attempted to contact) all first tier suppliers to set out our zero-tolerance stance on modern slavery and to ensure that slavery and/or human trafficking is not taking place.

Hublsoft has taken action to monitor reports of modern slavery and will cross reference such reports with our first-tier supply chain. Hublsoft will seek to discontinue business with any first-tier supplier found by the enforcement authorities to be involved in modern slavery.

Hublsoft encourages use of its whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.

Training

Upon commencement of employment, all employees undergo a structured induction programme. All employees are made aware of Hublsoft policies relating to standards of behaviour that it requires from them. In its statement for the previous financial year, Hublsoft set itself a target of ensuring that 100% of new starters would complete their induction within two weeks of commencement of employment, of which 100% did complete within this target. Hublsoft also provides training on awareness of modern slavery to those within Hublsoft who have been identified as having responsibilities in this regard, namely those involved in finance and procurement. Hublsoft ensures that annual update training is provided.

Assessment of effectiveness in combatting modern slavery

To ensure effectiveness in combatting modern slavery, Hublsoft maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.

Following a review undertaken for Hublsoft’s statement of the previous financial year, Hublsoftconfirms its supplier list is upto date for the current financial year.

As in the previous financial year, there have been no reports that any of Hublsoft’s suppliers have been involved in activities covered by the Modern Slavery Act.

Concerns

All concerns regarding modern slavery should be addressed to the CEO. There is an annual review of Hublsoft’s obligations towards eradicating modern slavery within its organisation and supply chains.

Anti-Slavery Statement | Last Revised - 16 September 2020