Boxxe Modern Slavery Statement

Organisational structure and supply chains

Boxxe Limited (“boxxe”) is a privately owned entity incorporated in the UK. We provide corporate and public sector organisations with hardware, software, and services across a range of technologies including cloud, datacentre, workplace and security. Our customers, who are based predominantly in the UK, trust our in-house teams to deliver consultancy and managed services which support and enhance a broad range of industry leading and innovative technology partners. We also work alongside several specialist external services partners to underpin and amplify our own teams. Whilst the boxxe group has offices across the UK, our approximately 200 people are equipped to work anywhere in the UK. Our heritage is providing secure services to public sector organisations whilst also delivering technology solutions to small, mid-market and enterprise corporate customers.

Introduction to the Modern Slavery Act

The Modern Slavery Act 2015 (the “Act”) requires each business in the UK with an annual turnover of over £36 million to publish a transparency statement which sets out the steps they have taken to ensure there is no modern slavery in their supply chain or within their own business.

Our policy on modern slavery and human trafficking

We have an absolute zero tolerance policy to modern slavery. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our policy reflects our broader commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place within our business or supply chains.  

We understand that modern slavery encompasses:

1. Forced or compulsory work, through mental or physical threat;

2. Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;

3. Being dehumanised, treated as a commodity or being bought or sold as property; and/or

4. Being physically constrained or having restriction placed on freedom of movement.

Commitment

1.  We acknowledge our responsibilities under the Act, and we are committed to preventing slavery and human trafficking within our businesses and our supply chains. We understand that this requires an ongoing review of our internal practices and continual due diligence of our supply chains.

2. As part of our zero-tolerance policy, we will not enter into business, and will discontinue any current business, with any other organisation which knowingly supports or is found to involve itself in slavery, servitude or forced or compulsory labour.

We will strive to ensure that no labour provided to us in the provision of our services is obtained by means of slavery or human trafficking. As an equal opportunities’ employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our employees. This is also required from our suppliers as set out in our Supplier Code of Conduct.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion. We adhere to all relevant employment legislation in the United Kingdom. All employees are paid at least the UK minimum wage and in London all employees and contractors are paid the London Living Wage.

Further, boxxe actively supports a not-for-profit in the anti-slavery community in a range of ways including, running an ongoing toiletry donation box in the boxxe York office, organising for the NGO to run an online awareness session with employees to spot the signs of modern slavery as well as offering volunteering opportunities to boxxe employees at the NGO’s centre. 

Our due diligence processes

Our processes are designed to:

1. establish and assess areas of potential risk in our business and supply chains;

2. monitor potential risk areas in our business and supply chains;

3. reduce the risk of slavery and human trafficking occurring in our business and supply chains; and

4. provide adequate protection for whistleblowers.

To ensure that this policy is adhered to, we implement the following processes:

1. boxxe has a strict process of supplier selection and ongoing review, through its Supplier Management team.
2. During onboarding, we engage with all our suppliers to convey the contents of this policy to them and we ask them to confirm by way of a signed statement that they have read and understood our policy and will adhere to it.
3. We review each of our suppliers to establish what steps, measures and practices they have implemented to prevent modern slavery occurring in their organisations. As a reseller of goods and services and not a manufacturer, we expect our suppliers to self-audit and monitor their supply chains and provide us with that evidence as part of their onboarding.
4. We include contractual provisions into our supply contracts where appropriate to confirm that our suppliers adhere to the Act and that they accept our policy.
5. We make it mandatory to discontinue business with any supplier found to have been involved in modern slavery (upon us becoming aware of such).
6. We undertake the Modern Slavery Assessment Tool (MSAT) (a free modern slavery risk identification and management tool for public bodies to use with their suppliers) on an annual basis to ensure we are consistently striving to make improvements on our practices and procedures. 

Our effectiveness in combating slavery and human trafficking

As our attitude to modern slavery is zero tolerance, we have not adopted key performance indicators as any instance of modern slavery or human trafficking in our supply chain would be an unacceptable breach of our policy.

However, we will monitor our internal compliance with this policy by recording:

1. Which of our suppliers have read and agreed to adhere to our policy;
2. Which of our suppliers have implemented their own policies and procedures with prohibitions against modern slavery; and
3. Which of our suppliers' place obligations on their own employees to comply with their modern slavery policies.

Where our suppliers do not yet have modern slavery policies and procedures in place, where appropriate we will ask for confirmation as to the likely timescale for their introduction. 

Where we have identified a potential risk (for example, a breach within a supplier’s own supply chain), we will ask the supplier to provide further evidence in order to make an assessment as to the viability of working with the supplier. If the risk can be mitigated or resolved, boxxe documents this and will continue to work the supplier (if necessary, subject to certain conditions or caveats around improved procurement practices and/or industry collaboration). However, if the risk cannot be mitigated or resolved, we enforce a strict code of compliance so a failure to comply with this policy will result in the termination of our contract with the supplier.

We also commit to procedures to ensure adequate procurement pricing and prompt payment, which is demonstrated in our published Supplier Code of Conduct. We are signed up to the Prompt Payment Code administered by the Office of the Small Business Commissioner on behalf of BEIS and as such will endeavour to undertake all payment activities in line with the guidance set out in the code.

In addition, within our own business to determine our effectiveness, we:

1. Assess the effectiveness of our training:  We assess completion rates of our compulsory modern slavery training course and follow up with individuals where necessary to ensure compliance.

2. Internal Review of our policies and procedures:  We regularly review our policies and procedures to ensure they are in line with regulatory requirements and best practice. This also includes reviewing our due diligence and ongoing monitoring procedures in relation to our suppliers.

3. External scrutiny:  Our modern slavery policies and procedures also come under external scrutiny and are assessed by our customers through bids and tenders’ processes and periodically through customer audit assessments, which set out to verify and understand our position around modern slavery.

Responsibility for our policy

boxxe’s Board of Directors are ultimately responsible for compliance with this policy, and the Board of Director’s are advised by the internal legal team. Any queries, questions or concerns regarding modern slavery can be addressed to both the legal team and the Board of Directors. The legal team will undertake an annual review of our obligations towards eradicating modern slavery within our organisation and supply chains.

Training

We invest in educating our employees to recognise the risks of modern slavery and human trafficking in our business and supply chains. All our employees are instructed to read this policy and confirm their understanding and agreement to comply with our policy to help in the identification and prevention of modern slavery. This policy is communicated internally to all employees after publication on boxxe’s website publicised to raise awareness. New employees will receive training on modern slavery as part of their induction process. In addition, all our employees responsible for compliance or procurement will be trained on an annual and ongoing basis on the requirements of this policy. All employees are encouraged to identify and report any potential breaches of this policy.

Risk assessment and management

boxxe has a risk-based methodology in place to ensure its suppliers comply with the Act.  Given the nature and locations of our business, we consider ourselves to be at low risk of the potential for slavery or human trafficking. We also believe that our business model and strategy is unlikely to create material risks of slavery and human trafficking. We have a number of procedures in place which we consider to be effective to prevent modern slavery from occurring in our business or supply chains.

Approval

This statement is made pursuant to section 54(1) of the Modern slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2023 and is approved by the Board of Directors of Boxxe Limited.