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MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT


Introduction

It is a priority for Gibbs Hybrid Programme Solutions Consultancy Limited (“Gibbs Consulting”) to ensure that we trade ethically, source responsibly and work to prevent modern slavery and human trafficking throughout our Organisation and in our supply chain.

Our staff receive training that enables them to identify signs of trafficking and modern slavery as part of our procedures and enable them to take swift action should this be necessary. We are taking appropriate measures to ensure that everyone who works for us benefits from a working environment in which their fundamental human rights are respected and anyone we do business with also upholds these principles.

Organisation’s structure/Our business

We provide a range of innovative statement of work solutions that can meet the needs of your technology and business-enabled programmes across Infrastructure and Operations, Cloud Services, Cyber Security, AI & ML and Data Science & Analytics. Underpinning our services are three foundational pillars: Architecture, Quality Assurance and Automated Deployment. We deliver flexible, on-demand IT Services and Statement of Works via T&M, Milestones, Deliverables and/or Outcome-based service models.

We are a part of the Atrium Group of companies (Group). The Group has over four hundred employees worldwide and operates across the UK, Europe, Middle East & Africa, and US.

Our supply chains

Our supply chains largely consist of companies, individuals and consultancies that provide the services and goods that enable us to operate our business.

Definitions

The Organisation considers that modern slavery encompasses:

– Human trafficking

– Forced work, through mental or physical threat

– Being owned or controlled by an employer through mental or physical abuse of the threat of abuse

– Being dehumanised, treated as a commodity or being bought or sold as property

– Being physically constrained or to have restriction placed on freedom of movement.

Our policies on slavery and human trafficking

We have appropriate policies in place that underpin our commitment to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies.

Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Due diligence processes for slavery and human trafficking

As part of our initiatives to identify and mitigate the risk of modern slavery and human trafficking, we have a robust supply chain compliance programme and all suppliers are subject to due diligence and strict compliance checks to ensure compliance with statutory requirements and industry sector best practice. Due diligence is also undertaken on all candidates and this includes (but is not limited to) identity verification and right to work checks.

We also have in place systems to:

– Identify and assess potential risk areas in our supply chains.

– Mitigate the risk of slavery and human trafficking occurring in our supply chains.

– Monitor potential risk areas in our supply chains.

– Protect whistle blowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain comply with our values, ethics, policies, statutory requirements, and industry sector best practice, these are incorporated into all our agreements with suppliers as contractual obligations.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide regular training to our staff. We also require our business partners to provide training to their staff, suppliers, and providers.

Key Performance Indicators

Gibbs Consulting has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

– Review modern slavery risks in our supply chain.

– Incorporate modern slavery training into our annual employee training schedule.

– Improve supplier awareness of our modern slavery policies and procedures by including and sharing our modern slavery statement when engaging clients and suppliers.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 December 2023.

Farida Gibbs, CEO, Gibbs Hybrid Programme Solutions Consultancy Limited, May 2024

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