Last updated: October 2024

Introduction

Modern slavery is a crime and a violation of fundamental human rights, depriving a person’s liberty in order to exploit them for personal or commercial gain.

The Modern Slavery Act 2015 (referred to henceforth as “the Act”) was introduced to help eradicate slavery, forced labour and human trafficking in company operations and supply chains.

This statement is made pursuant to the section 54(1) of Modern Slavery Act 2015.

Our commitment

Cloud Gateway acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Cloud Gateway does not enter into business with any other organisation, in the UK or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Cloud Gateway in pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, and in many cases exceeds those minimums in relation to its employees.

Our commitment is set out in further detail in our Modern Slavery policy.

Supply chain compliance

We expect the same commitment and standards from our contractors, suppliers and business partners. We will never work with organisations who knowingly support or are found to be involved in slavery, servitude and forced or compulsory labour.

Contractual requirements will be mandated through our contracting agreements to highlight our expectations. Supplier reviews ensure that ongoing compliance is managed.

Report

Our organisational structure and supply chain

We are a privately-owned company offering networking and security solutions to the public and private sector.

We directly employ over 34 staff across the United Kingdom who work a hybrid model, with offices “hubs” in London and Manchester.

We are confident that our own operations are free of modern slavery, forced labour and human trafficking.

Our supply chain consists predominantly of very well-known, UK-based networking hardware manufacturers and Software as a Service (SaaS) providers.

Our modern slavery policies and initiatives

It is our policy to ensure that all prospective staff are legally entitled to work in the United Kingdom prior to commencement of contract. We also have policies and procedures in place to ensure that our employees are fairly treated and that our working environment is non-discriminatory and respectful.

Such policies include:

• Equity, inclusivity and diversity policy

• Anti-harassment policy

• Whistleblowing policy

We endeavour to maintain a culture where employees feel safe exposing any wrongdoing without any risk to themselves.

Our due diligence procedure regarding modern slavery in our supply chain

As part of our approach to maintaining an ethical supply chain free of modern slavery, we conduct due diligence assessments. Identifying and taking a record of our supplier’s Modern Slavery Statements and/or commitments contributes to these assessments. Reassessments and performance reviews ensure that ongoing compliance is managed.

How we ensure the success in guaranteeing that human trafficking and slavery is not taking place in our supply chain.

Contractual agreements mandate and highlight our expectations with regards to upholding the Act. We require that suppliers report any suspected or actual breach of the Act associated with our contract to us immediately. We reserve the right to terminate contracts in the event of non-compliance.

Where any concern is raised with a supplier, we will seek to offer guidance to tackle any issues. If progress remains minimal, our engagement will be carefully reviewed. The number of suppliers we choose to terminate engagements as a direct result of compliance with the Act will be recorded in subsequent Modern Slavery Statements.

The training we provide to our staff

Modern slavery awareness forms part of our onboarding process for all staff. Awareness raising ensures that employees understand our expectations of them, in that they must report any suspected or actual breach of the Act as soon as they possibly can.

Our Whistleblowing Policy also includes guidance for staff in reporting any suspicion of inappropriate or illegal behaviours.

Breach reports and contract terminations

We have not received any reports of potential or actual breaches of the Act. Furthermore, no procurements or contracts have been terminated as a result of concerns regarding compliance with the Act.

Updates from last year’s report

In the last reporting year, we have:

• Continued to review our due diligence assessments to include reviewing our supplier’s Modern Slavery statements

• Updated references to Modern Slavery in our contracts

• Attended webinars to increase understanding in this area

• Included Modern Slavery in our onboarding and inductions for new employees

Future plans

Although future initiatives are subject to change, we are committed to continually improving our processes and initiatives with regards to modern slavery. Potential future projects and plans include:

• To complete the application process and become an accredited Living Wage Employer

• To register with the Home Office Modern Slavery Registry

• Heighten the level of scrutiny with regards to modern slavery throughout our

  supply chain

• Enhance mandatory training for the departments overseeing high risk area

  suppliers to raise further awareness

Slavery Compliance Officer

Cloud Gateway has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.