Introduction

The Modern Slavery Act 2015 (the ‘Act’) requires each business with an annual turnover of over £36m to publish a transparency statement which sets out the steps they have taken to ensure there is no modern slavery in their own business and in their supply chains. This statement is made pursuant to the Act.

We strive to be a great place to work for Elite Enterprise Software people. We want our employees to be fully engaged with our Company and motivated to give their all and we want their contribution to be recognised and rewarded.

We will therefore not tolerate forced, bonded or compulsory labour, human trafficking and other kinds of slavery within our own operations or within our supply chain and we are committed to taking appropriate steps to ensure that everyone who works for Elite – in any capacity – benefits from a working environment in which their fundamental rights and freedoms are respected.

Our approach to preventing modern slavery forms part of our wider corporate responsibilities, for which I am responsible as CEO. We adopt procedures that contribute to ensuring modern slavery does not occur in our business or supply chains and we expect organisations with whom we do business to adopt and enforce policies to comply with the relevant legislation.

Our structure and supply chains

Elite Enterprise Software Limited is a company incorporated in the UK with one subsidiary company incorporated in the Lithuania. Our customers are predominantly located in the UK and Ireland. The branches Elite has established (UK, Lithuania and the Netherlands help our UK and Irish customers deploy technology solutions across their organisations.

We provide corporate and public sector organisations with software licensing, workplace technology, networking and security, and cloud and datacentre. We do not manufacture hardware, develop bespoke applications or specialise in any industry-specific vertical application but we can partner with third party organisations for these requirements.

We have approximately 31 employees, nearly all of whom work in the UK or Ireland.

We partner with different hardware and software vendors to bring the latest and broadest range of technology to our customers, as well as numerous specialist service providers to augment the services provided by our in-house teams.

The majority of our business comes from the small to medium-sized business segment and public sector customers. We also serve large enterprise customers and the corporate mid-market.

Our procedures

Given the nature and locations of our business and operations, we consider ourselves to be at low risk of the potential for modern slavery or human trafficking. Furthermore, our revenues are predominantly derived from countries deemed low risk by conventional sustainability indices, such as The Global Slavery Index (http://www.globalslaveryindex.org/index/). We also believe that Elite’s business model and strategy is unlikely to create material risks of slavery and trafficking.

We have a number of procedures in place which we consider to be appropriate to our business and effective in preventing modern slavery from occurring in our business and our supply chains.

Employment

• We treat our employees in a fair, lawful and professional manner and provide for fair working conditions, including health and safety holiday entitlements and benefits.
• Robust recruitment processes are taken in line with employment laws, including:
• ‘right to work’ document checks;
• contracts of employment, available to the employee at all times; and
• checks to ensure everyone employed is 16 and above.
• We make sure our people are aware of their contractual and statutory employment rights.
• Market-related pay and rewards are reviewed annually.
• We are an accredited Real Living Wage Employer.
• We consider and address circumstances where there may be a higher risk of modern slavery. For example, we work with our office cleaning agencies to ensure that all contracted cleaners receive a real living wage.

Transparency in our supply chains

As part of our initiative to identify and to mitigate risk:

• We have sought confirmation by our top suppliers (who work for us providing products and/or services for our own business use), in terms of spend, of their compliance with the Act.
• We operate a Supplier Code of Conduct which addresses the labour rights issues associated with modern slavery and sets out the values and standards we expect of our suppliers. Suppliers must agree to comply with the Code as part of our improved on-boarding process, ensuring a minimum standard is required by our direct suppliers.
• If a supplier cannot agree to comply with our Supplier Code of Conduct, our approach is to maintain a dialogue and develop an action plan with the supplier in question with the aim of bringing their procedures and policies in line with the standards that Elite upholds.
• Employees who are involved in the onboarding process in the Procurement function are given on the job training to help ensure the process is performed correctly; this training will be expanded in 2023 to include modern slavery awareness.

Supporting our people

• Our Employee Handbook requires all of us to act ethically and we expect employees to comply with legal requirements at all times, putting our values into practice in everything we do.
• We have a speak-up hotline to enable anyone who has concerns (for example, how suppliers, customers, partners or employees behave) to raise their concerns confidentially.

Further steps

We plan to implement the following in 2023 to further guard against the risk of modern slavery and trafficking:

• Additional awareness training for other departments deemed to have an (albeit minor) exposure to modern slavery risk.
• A review of our Supplier Code of Conduct, to ensure provisions against the risk of modern slavery remain in line with good practice, and implementation of an annual review process.
• A review of our terms and conditions documentation, which will include a direct reference to adherence with modern slavery legislation.
• Take steps to improve our ongoing due diligence procedures in relation to modern slavery risk in our supply chain.
• Develop a formal policy for the procurement of merchandise and other marketing materials from suppliers to re-enforce the importance of sustainability as well as working with those who have acceptable employee practices.