Last updated: July 2023

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 is committed to principles of the Act, and the eradication of modern slavery and human trafficking. We act ethically in all our operations and ensure modern slavery is not taking place anywhere in our business or our supply chain.

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 35 staff across the UK who work remotely, although office “hubs” are available for those that wish to work from an office environment on occasion.

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

Such policies include:

• Modern slavery policy

• Equity, inclusivity and diversity policy

• Health and safety policy

• Anti-harassment policy

• Whistleblowing policy

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 a due diligence assessment on all suppliers. Identifying and taking a record of our supplier’s Modern Slavery Statements and/or commitments contributes to these assessments.

Contractual requirements will be mandated through relevant contracting agreements to highlight our expectations with regards to upholding the Modern Slavery Act 2015.

Supplier performance reviews ensure that ongoing compliance is managed.

The steps we are taking to diminish the risk of human trafficking and slavery in our supply chain

We contract with a range of suppliers. Our full supplier management process allows us to conduct due diligence prior to engagement, as well as continued performance and compliance reviews throughout it. Such reviews enable us to have open discourse with our key suppliers at minimum.

Contracts state our position and obligations we pass on to suppliers. The contracts are also reviewed during performance reviews.

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

Through our agreements with suppliers, we require that they 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 with will be recorded in subsequent Modern Slavery Statements.

The training we provide to our staff

All staff are required to complete a mandatory modern slavery awareness training. 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. Understanding of the Act is communicated so that they are able to identify any possible exploitations.

The Modern Slavery policy and this statement are also actively shared with all staff to help colleagues understand their responsibilities.

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:

• Updated our annual supplier check program to include reviewing our supplier’s Modern Slavery statements

• Updated our supplier management process to include ongoing checks in this regard

• Conducted a Maturity Assessment with an independent consultant to advise on our progress and journey with regards to ESG (environmental, social and governance) initiatives

• Updated references to Modern Slavery in our contracts

• Reviewed our policies and statements

Future plans

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

• Review enhancing mandatory training for the departments overseeing high risk area suppliers to raise further awareness

Review

This report will be reviewed and updated annually.