Modern slavery statement

• Introduction

  It is Doherty Associates’ (DA or the Company) policy to conduct business in an honest and ethical manner.

  This statement sets out DA’s actions to understand all potential modern slavery risks related to its business. It also puts in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business as well as in its supply chain.

  This statement relates to actions and activities during the financial year 1 January 2022 to 31 December 2022.

  As part of the Information Technology sector we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. Although we are not required by law to produce this statement, DA considers preventing slavery and human trafficking as imperative in its corporate activities, which includes ensuring that our supply chains are also free from slavery and human trafficking.

• Definition

  The Company considers that modern slavery and human trafficking includes recruitment or movement of people for exploitation by the use of threat, force, fraud, or the abuse of vulnerability.

• Scope

  This statement covers the activities of DA:

  • The Company is an IT Managed Services provider operating globally
  • Our main method of delivery of services is via the people we employ, either as engineers providing support services or consultants delivering projects to our clients
  • The Company also purchases services on behalf of our clients on a reseller basis as well as purchasing some services that enable the delivery of our IT solutions to clients
• Organisational structure and supply chains

  Countries of operation and supply

  We currently operate in the following countries:

  • United Kingdom – our head office is based in London, we deliver support and consultancy services from this location
  • Malaysia – our subsidiary office is based in Kuala Lumpur, out of which support services are delivered

  The Company assesses whether or not particular activities or countries are high risk in relation to modern slavery.

  High-risk activities

  The following activities are considered to be at high risk of slavery or human trafficking:

  • There are no activities undertaken by the Company that are high risk of modern slavery or human trafficking
• Responsibility

  Responsibility for our initiatives addressing Modern Slavery and Human Trafficking are as follows:

  • Policies: The Board of Directors is responsible for putting in place and reviewing policies and processes
  • Training: Modern Slavery and Health and Safety training is mandatory for all staff (during onboarding and then, on an annual basis, and/or due to role change)
  • Culture: Active encouragement to report unethical behaviour or signs of modern slavery and promoting the benefits of reporting and shared accountability
  • Due diligence (suppliers): In our Purchasing and supply chain management activities, our Procurement team are responsible for undertaking due diligence activities
  • Due diligence (employees): In our own operation, the DA Human Resources team are responsible for ensuring that all due diligence checks are undertaken during all the stages of employment, from initial recruitment onward
• Due diligence (employees)

  To ensure that there is no Modern Slavery or Human Trafficking within DA we have taken the following interventions:

  • All employees have a contract of employment that sets out their Employment Rights and Obligations including the notice period needed for them to terminate the contract and leave our employment. Employees are free to serve notice at any time
  • We verify employee’s identity and ongoing right to work in the UK
  • We do not withhold any employee’s physical identity documents (e.g. passport) during their Employment
  • We comply with all legislation in respect of working time and statutory time off, holiday entitlement, time off for personal emergencies, sickness and maternity/paternity leave and minimum rest breaks and periods
  • We have introduced training to make employees aware of their rights and how to spot and report signs of Modern Slavery and Human Trafficking
  • There is an annual reward review process and the business is in the process of becoming an accredited Living Wage Employer
• Approach to Preventing Modern Slavery and Human Trafficking

  The following policies define the interventions we have taken to prevent Modern Slavery and Human Trafficking in our operations and direct supply chain.

  • Whistleblowing policy
  • Anti-harassment policy
  • Equality, Diversity and Inclusion policy
  • Corporate Social Responsibility policy
  • Anti-bribery policy
  • Grievance policy
  • Employee conduct policy
  • Supplier code of conduct
  • Recruitment and Selection policy
• Performance indicators (KPIs)

  The Company takes action to identify, mitigate and mange Modern Slavery and Human Trafficking risks in its supply chains. The specific KPIs for 2022/23 are outlined below:

  Commercial capability

  KPI 1 – 100% of staff will have undertaken the Modern Slavery and Human Trafficking eLearning course by 31 December 2022. New joiners to undertake the course within one week of joining

  Employee rights

  KPI 2 – Whistleblowing mechanisms are in place and monitoring for cases involving Modern Slavery and Human Trafficking.

  Supplier engagement

  KPI 3 – Review existing supply chain by July 2022. Risk assessments are to take place on all new requirements. A process for supply chain verification has been in place since August 2021, whereby we evaluate potential suppliers before contracting.

• Embedding the principles

  We will continue to embed the principles through:

  • Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of Modern Slavery and Human Trafficking. We require all new staff in the UK to undertake Citation Modern Slavery in the UK training and then on an annual basis.
  • Ensuring staff involved in procurement activity are aware of and follow the modern slavery procurement guidance on GOV.UK
  • Continuing to take action to embed a zero tolerance policy towards Modern Slavery and Human Trafficking

  Apart from providing training and embedding policies to support prevention of Modern Slavery and Human Trafficking, staff are being made aware of other external resources for example the Modern Slavery Helpline.

• Board approval

  This statement was approved on 6 June 2022 by our board of directors, who review and update it annually.

• Monitoring and review

  The Company monitors the effectiveness and reviews the implementation of this policy at appropriate intervals, considering its suitability, adequacy and effectiveness. Any improvements identified are made as soon as possible.