MODERN SLAVERY & HUMAN TRAFFICKING POLICY

 

Blue Lights Digital

Modern Slavery and Human Trafficking Statement

January 2022

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 4th Jan 2021 & 4th Jan 2022

The statement sets down Blue Lights Digital Ltd commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Blue Lights Digital which are as follows:

Public and Private investigations, Training, Software development, Consultancy and the supply of technology & services. This includes diligence and references of all companies used in the supply or subcontract of Blue Lights Digital Services.

The Company has operated in the following geographies in the last year:

  • European Union
  • Nordics
  • The continent of Africa
  • United States of America
  • The Caribbean
  • The Middle East
  • The Association of Southeast Asian Nations
  • South Korea
  • India
  • Bangladesh

The following is the process by which the Company assesses whether activities or countries are high risk in relation to modern slavery or human trafficking:

High Risk Activities

The following activities are considered to be at high risk of modern slavery or human trafficking:

  • The training of Police tactics and investigative processes
  • The supply of intelligence solutions
  • The supply of digital forensic solutions

Responsibility for the Company’s anti-slavery initiatives is as follows:

1.1 Policies: The Directors are responsible for creating and reviewing policies. The process by which policies are developed are in collaboration with the authorities and companies that Blue Lights Digital engage with.
1.2 Risk assessments: The Directors are responsible for risk assessments in respect of human rights and modern by a process of use of Due Diligence questionnaires and commercial compliance to contractual commitments.
1.3 Due diligence: The Directors are responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to
attend a compulsory training session on an annual basis.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations

2.1 Whistleblowing policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
2.2 Company Code of Conduct – The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
2.3 Company Social Responsibility (CSR) Policy – The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes Open-Source Intelligence (OSINT) and building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

Performance indicators

The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all relevant staff to have completed training on modern slavery by their 3-month employment anniversary use of labour monitoring and payroll systems.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary by the board of Directors who endorse this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by to company board.