Modern Day Slavery Policy Statement

The Modern Slavery Act 2015 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.

Insurgo has a zero-tolerance approach to any form of modern slavery and is fully committed to playing its part in eliminating modern slavery and to maintain and improve its systems and procedures to ensure that there is no complicity in human rights infringements in its operations and those of its supply chain. 

Insurgo recognises that slavery and human trafficking can occur in many forms. Therefore, throughout this statement, the term “modern slavery” is intended to encompass all forms of coerced labour.

This statement refers to the financial year ending 31st July 2020 and sets out the steps taken to prevent modern slavery and human in Insurgo’s business operations and supply chains.

About Insurgo

Insurgo is an industry leader in providing complete tape and data lifecycle management solutions for organisations across the globe and currently employs 18+ members of staff.  Insurgo’s headquarters are based at Roseheyworth Business Park, Abertillery, South Wales.  

Our Supply Chain

Insurgo operates a number of policies that reflect our objective to act ethically and in compliance with our legal and regulatory obligations with regard to our employees, customers and business relationships.

Our supply chains provide goods, materials and services and the company takes all possible steps to verify, evaluate and address risks of slavery and human trafficking in our supply chains. Responsibility for ensuring that this happens is held with the Directors of Insurgo.

Due Diligence

Insurgo ensures that appropriate due diligence is conducted by assessing all suppliers across a number of key risk areas.  The company is committed to engaging only with those suppliers that uphold the same principles as us.   

The company’s verification process involves annual reviews with our suppliers and partnership agreements, allowing greater transparency through partnership working. 

Insurgo also participates in regular audits (both internal and external) as part of its supply chain management process. 

The company operates a robust recruitment policy including conducting eligibility to work in the UK checks for all directly employed staff, and agencies on approved frameworks which are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will.

Insurgo encourages anyone, including employees, contractors, suppliers and customers, to report in good faith any issues or concerns about potential ethical, human rights, legal or regulatory infringement.  The company’s policies and procedures explicitly interprets Insurgo’s approach to Anti-Bullying, Harassment, Anti-Fraud, Bribery and Corruption, Equality and Diversity and Whistleblowing.

Risk Assessment 

The industry in which Insurgo operates does not have a high risk of modern slavery, however, a risk-based approach has been adopted to review its supply chains that fall within industries that carry a high risk of modern-day slavery. 

Suppliers are reviewed on an annual basis to identify those with the highest potential risks of modern slavery.  

Measuring Effectiveness

The company’s HR, Quality and Recruitment departments are involved with ensuring annual checks are undertaken of all employees’ employment status and conditions of employment.  This happens without exception upon recruitment and regularly on at least an annual basis. 

Training 

Insurgo conducts regular training sessions to ensure a high level of understanding of the risk of modern slavery and human trafficking both in our business and supply chains.  Training is also provided to relevant employees on the legal provisions and requirements relevant to our business activities.    

Managers at Insurgo receive further training to ensure knowledge and understanding in management guidance to ensure consistency in our management of suppliers, recruitment process, fair treatment at work and inclusion and diversity.  

Director Approval

The Directors are responsible for ensuring Insurgo has the appropriate policies in place to meet its obligations under the Modern Day Slavery Act 2015.  

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes the company’s slavery and human trafficking statement for Insurgo’s current financial year.

This statement has been produced and approved by the Directors of Insurgo. 

Version 1.2  January 2020