Introduction
This document sets out the policy of Ada Mode Limited with the aim of the prevention of opportunities for modern slavery to occur within its businesses or supply chain.
Ada Mode is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain. Ada Mode insists that the same standards that it promotes in combatting modern slavery are similarly adopted and enforced by its suppliers in order to adhere to the obligations and the intent of the Modern Slavery Act 2015 (“the Act”).
Slavery and human trafficking are a reprehensible blight on our global society. We all have a responsibility to be alert to the risks in our business and in the wider supply chain. Employees are expected to report concerns and management are expected to act upon them.
Modern slavery is a criminal offence under the Modern Slavery Act 2015. Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
This policy's use of the term 'modern slavery' has the meaning given in the Act.
Our Business
Ada Mode provides consultative services and digital products that improve the performance of complex industrial processes through AI, data science, engineering expertise and design thinking.
Ada Mode Limited operates in the UK. We employ under 20 people with a turnover <£5 million and utilise two serviced offices in England.
Our Supply Chains
Our supply chains include one or more companies in the following categories:
• Recruitment agencies
• Associates
• Various professional services (legal, accounting, marketing, branding etc.)
• Serviced offices
• IT Hardware (laptops, mobile phones etc.)
As part of considering suppliers and ongoing monitoring of our supply chain, we carry out regular reviews to ensure suppliers are assessed and the information held on our supplier register is kept up to date.
Our Policies on Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in our business.
Our Anti-Slavery Policy reflects our 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 anywhere in our supply chains.
Due Diligence for Slavery and Human Trafficking
As part of our initiatives to identify and mitigate risk:
• We require all of our employees (contracted or otherwise) to be aware of their responsibilities under the Modern Slavery Act, through review of this policy and further reading of the Modern Slavery Act if required, and require them to adhere to all good business practices that ensure compliance;
• Where possible, we build long standing relationships with local suppliers and customers and make clear our expectations of business behaviour;
• We expect our suppliers to have suitable anti-slavery and human trafficking policies and processes in place. We expect each entity in the supply chain to, at least, adopt 'one-up' due diligence on the next link in the chain. It is not practical for us (nor every other participant in the chain) to have a direct relationship with all links in the chain.
Supplier Adherence to our Values
We have zero tolerance to modern slavery and human trafficking. We expect all those in our supply chain and contractors will comply with our values. The Directors are responsible for compliance in their employees and for their supplier relationships.
Training
We make our employees aware of the risks of modern slavery and human trafficking in our business and supply chains. Our employees, particularly in parts of the business which manage our supply chain, are encouraged to identify and report any potential breaches of the Act or suspicions of slavery and human trafficking within the Ada Mode Limited UK supply chain.
Our Effectiveness in Combating Slavery and Human Trafficking
We use the following performance indicators to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
• Monitoring of payroll system; and
• Levels of communication and personal contact with next links in the supply chains and their understanding of, and compliance with, our expectations.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Ada Mode Limited’s slavery and human trafficking statement for the financial year ending 31st March 2022.
Ada Mode Limited Registered in England & Wales no. 12351326
Registered office: 77-81 Alma Road, Clifton, Bristol, BS8 2DP