MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2020-2021
MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT 2020-2021
Over the past year New Blue Chip Limited and its subsidiaries (“Blue Chip”) has continued a zero tolerance approach to slavery and human trafficking of any kind and focussed attention on ensuring effective due diligence across our ever growing base of suppliers. We have also introduced a clear concise Code of Conduct for suppliers, based on the same values applied to our own employees, to ensure there is no confusion as to the standards we expect from our supply chain.
Our supplier relationship function remains key to the above achievements and now reports directly into our Chief Compliance Officer as part of ensuring it has appropriate Board level sponsorship. Blue Chip is also proud of its multi-cultural employee base, and we continue to provide opportunities in the UK for staff from our Sri Lankan office as well developing the skills of those new to employment with our apprenticeship programmes that include competitive salaries and Blue Chip funded education.
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 230 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 £46 million for the company financial year ended 30th September 2019.
Our Business Operations
Blue Chip has built its business based on the provision of total system support services for users of IBM technology, including hardware maintenance and disaster recovery services, software support, and managed 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.
Whilst continuing to focus on the United Kingdom as a core market, including local entities for multi-national organisations, Blue Chip is continuing to expand 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, irrespective of geography.
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, logistics and transport suppliers, 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
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.
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.
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.
As per the commitment in our previous annual Statement we have published new standard terms and conditions of purchase available at https://www.bluechip.co.uk/files/standard-terms-and-conditions-for-goods... which require suppliers to Blue Chip to comply with all UK anti-slavery and human trafficking laws, whether the supplier is based in the United Kingdom or not. Blue Chip also reserves the right to audit a supplier’s adherence and how they manage their own supply chains.
Due Diligence Processes for Slavery and Human Trafficking
Blue Chip’s supplier management function which reports directly into our Chief Compliance Officer, provides an internal governance and due diligence function on slavery and human trafficking at both operational and leadership levels. This governance structure is designed to identify and assess potential risk areas in our supply chain, mitigate the risk of slavery and human trafficking occurring, and 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 confidentially and without detriment.
As per the commitment in our previous annual Statement Blue Chip has contacted its supply chain,, irrespective of whether they supply goods or services, and is in the process of collecting copies of relevant policies, where relevant their slavery and human trafficking statement and/or 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 based on its response to Blue Chip’s due diligence requests. 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 is 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 and its relationship with Blue Chip.
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 have published a Code of Conduct for suppliers, business partners and subcontractors on our website at https://www.bluechip.co.uk/supplier-terms-conditions that all companies are required to contractually commit to in accepting orders for goods and services from Blue Chip.
The Code of Conduct addresses not only slavery and human trafficking obligations, but also ensure compliance to ethical business practices in general and commitment to climate friendly practices in general. The Blue Chip Standard Purchase Terms used on Purchase Orders have also been updated so that ad hoc suppliers engaged on a transactional basis are also captured.
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. To ensure continued understanding of topics such as the risk of modern slavery and human trafficking in the Blue Chip business and our supply chain, we provide awareness updates to staff on relevant enforcements including the Modern Slavery Policy.
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 are 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 2019 has been approved by the Board of Directors of Blue Chip.
20th March 2020