MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2019-2020
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2019-2020
New Blue Chip Limited and its subsidiaries (“Blue Chip”) is proud of its commitment to operating its business and services in a manner that satisfies not just legal and regulatory requirements, whilst delivering market leading quality, but in a manner that is both ethical and environmentally friendly. We are committed to treating all our employees fairly and equally in all respects, and actively work to ensure the same applies in all organisations in our supply chain. Blue Chip has a zero tolerance approach to slavery and human trafficking of any kind.
No industry is completely insulated from the risks and effects of slavery and human trafficking, and we recognise it is incumbent on each business to do what it can to drive it out. Our supply chain, which is extensive and global, is potentially exposed to these risks and effects, so a key objective of our supplier relationship function is to ensure suppliers are aware of and meet our expectations and combat slavery and human trafficking, whether they are manufacturing hardware, developing software, or providing specialist technical support services.
About Blue Chip
Blue Chip is a leading provider of data centre and IBM support services across all industry sectors. Founded in 1987 as a provider of IBM hardware maintenance services, Blue Chip has grown organically to become the largest independent provider of IBM support services outside of the manufacturer with around 235 employees, mostly based in the United Kingdom.
Blue Chip also has a fully owned subsidiary based in Sri Lanka focussed on providing in house software development capabilities and basic operational support for selected customers to enable managed service delivery 24 hours a day 365 days a year. Blue Chip had an annual global turnover of £45 million for the company financial year ended 30th September 2018.
Our Business Operations
Blue Chip has historically focussed on provision of total system support services for users of IBM technology, including basic hardware maintenance services, disaster recovery, managed services and infrastructure services based out of the company’s two data centres located near Bedford in the United Kingdom. Blue Chip also provides hardware, software and professional services to assist customers who have not outsourced their information technology environment.
Although the previous focus has been on the delivery of services within the United Kingdom, this has included major multi-national companies. Blue Chip is now expanding its hardware maintenance operations into the USA and Europe, placing more emphasis on effective use of a supply chain. The objective of Blue Chip’s supplier relationship function is not only to ensure service quality and performance, but to ensure supplier commitment to Blue Chip’s policies and business practices.
Our Supply Chains
The Blue Chip supply chain is broadly broken into a number of categories including new product supply (whether hardware or software), used product supply (for hardware spares), connectivity services, specialist technical support services, utility services (such as power), outsourced back office functions, and facility services such as cleaners.
Within the above Blue Chip has relationships with companies that service its customers as well as internal business operations. The length of some supply chains adds complexity to assessments as they must include recognition end to end of even the most extended chain, ie., not just the company supplying hardware but labour used to extract raw materials used in manufacturing of hardware.
Our Policies on Slavery and Human Trafficking
Blue Chip is committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, including implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.
Modern slavery refers to servitude, forced labour and human trafficking and Blue Chip recognises that it is a worldwide problem that can occur in any country throughout the globalised community, including in the United Kingdom. Blue Chip expects its employees to report any concerns and has a whistleblowing policy that ensures the confidentiality and anonymity of anyone reporting a violation they identify. All reports will be fully investigated and appropriate remedial actions taken
All Blue Chip policies are maintained by our Compliance Team, have clear ownership and are regularly reviewed. The expectation of the Blue Chip Board is that they will be promptly made aware of any concerns regarding slavery and human trafficking and that our management will act upon these reports accordingly. We also commit in our contracts with customers to assisting them with complying their reporting requirements under the Modern Slavery Act 2015.
Blue Chip is currently reviewing its standard terms and conditions of purchase, and the new document to be published in the coming year will require any supplier of goods and/or services to comply with all UK anti-slavery and human trafficking laws, whether the supplier is based in the United Kingdom or not. Blue Chip will also be reserving the right to immediately terminate any relationship if the supplier breaches its legal obligations in relation to slavery and or human trafficking.
Due Diligence Processes for Slavery and Human Trafficking
During the 12 months preceding this annual statement Blue Chip has focussed on addressing the risks of slavery and human trafficking across our business including our supply chain, via our supplier management function, forming an internal governance and due diligence structure on slavery and human trafficking at both operational and leadership levels.
The governance and due diligence structure is designed to identify and assess potential risk areas in the Blue Chip supply chain, mitigate the risk of slavery and human trafficking occurring in our supply chain, provide a basis for the ongoing monitoring of potential risk areas, providing policies for suppliers to adhere to, and a clear process for issues to be reported in a confidentially and without detriment.
Blue Chip is in the process of contacting all members of its supply chain, irrespective of whether they supply goods or services, requesting a copy of their policies in respect of slavery and human trafficking and where relevant their slavery and human trafficking statement and a signed commitment to exclude slavery and human trafficking from their supply chain. This includes assurances that appropriate controls and policies are in place, including within their own supply chain, and that appropriate due diligence checks have been performed as needed.
Information from the above process will provide the information required to enable Blue Chip to complete an initial risk assessment across the Blue Chip supply chain. We know that our greatest exposure to possible slavery and human trafficking is in the supply to us of hardware and in particular the supply of raw materials used to manufacture those products, but we are also aware of the risks associated with labour employed in the service sector, particularly when low skilled.
We have now mapped our supply chain to assess particular industry and sector-specific, as well as geographical, risks and at the time this annual statement was compiled, are in the process of assessing each supplier and allocating it with a risk level. Any supplier deemed of a high risk may be visited personally and a review undertaken of its operations in the context of compliance to anti-slavery and human trafficking requirements.
Each company in the Blue Chip supply chain will be required to notify us immediately on becoming aware of any indications of slavery or human trafficking in their business or supply chain, and we encourage a cooperative approach where issues are resolved together and proactively. Any suppliers in breach of its commitments will face appropriate actions which could include termination of contracts.
In addition to assessing the current Blue Chip business and supply chain, our supplier management and compliance functions have recently performed a complete review of our New Supplier Due Diligence Process and the related checks to be completed now include specific areas to gain assurance of ethical business operations, including in relation to slavery and human trafficking, before using a new supplier.
Supplier Adherence to Our Values and Ethics
Blue Chip has zero tolerance to slavery and human trafficking. In addition to continuing to build upon the due diligence activities described above, we intend to define a clear Code of Practice published on our website alongside this statement that all companies will be required to commit to prior to becoming part of the Blue Chip supply chain, and which will form part of their contract.
The Code of Practice will address not only slavery and human trafficking obligations, but also ensure compliance to ethical business practices in general and commitment to climate friendly practices in the manufacture and delivery of both goods and services. The Blue Chip Standard Purchase Terms will also be updated so that ad hoc suppliers engaged on a transactional basis are also captured.
Blue Chip has a dedicated Compliance Team that monitors the risks relating to slavery and human trafficking and in a recent organisational change our Supplier Relationship Function now reports into the Chief Compliance Officer emphasising and supporting the focus on ensuring suppliers meet their legal and other policy requirements as well as delivering contracted goods and services.
To ensure a high level of understanding of the risks of issues such as modern slavery and human trafficking in the Blue Chip business and our supply chain, we provide regular awareness updates to our staff on all policies including the Modern Slavery Policy. All Blue Chip staff are also notified whenever a policy is updated, with updates highlighting the significant changes to be reviewed. Our recruitment process and policy also defines our stance on slavery and human trafficking, both in making sure that new employees are aware of our policies and ensuring that our employment packages are fair.
Our Effectiveness in Combating Slavery and Human Trafficking
Blue Chip has elected to use a number of key performance indicators (KPI’s) to measure how effective we have been to ensure that slavery and human trafficking is not taking place on any part of the business or supply chain. The KPI’s will be based on measuring the processes discussed earlier in this annual statement and include the number of suppliers contacted, the number that have signed Blue Chip’s contract terms for slavery and human trafficking, the number that have been visited or had due diligence performed, and additionally the number of related concerns that have been reported, whether through normal management channels or via the whistleblowing procedure. We are committed to publishing an update on progress against the KPI’s in the next annual statement.
The directors of Blue Chip are ultimately responsible for compliance by the company and this statement reflects a number of initiatives and changes made to ensure we are continuing to ensure that slavery and human trafficking in any of its various forms, does not occur in our business or supply chain. We will continue to refine and strengthen our efforts to combat slavery and human trafficking and will continue striving to lead the way as a business that truly believes in ethical business practices.
This statement which has been made pursuant to Section 54(1) the Modern Slavery Act (2015), constitutes Blue Chip’ slavery and human trafficking statement for the financial year ending 30th September 2018 has been approved by the Board of Directors of Blue Chip.
21st March 2019