Modern Slavery Act 2015 | Novacroft Modern Slavery Statement for the financial year 2022-2023

This statement is made on behalf of Novacroft Group pursuant to the Modern Slavery Act 2015 (“the Act”) and
sets out the steps that Novacroft will take to ensure that modern slavery and human trafficking does not occur
within our business or supply chain.

Our Organisation

Charles Novacroft Direct Limited (“Novacroft”) registered in England (registered number 03601214).

We are a people-first company who specialise in customer experience transformation. We work in partnership
with clients in the public, private and third sectors to understand their challenges and help them rise to them.
Through process simplification, digital technology, and an amazing team we make a difference to the unique
needs of our clients’ customers whilst continuously delivering client success such as driving down costs,
unlocking efficiencies, and generating improvements and new opportunities for our clients to create value.

Our Approach

‘Modern Slavery’ is the use of forced, compulsory, trafficked or child labour. It has no place in our business. And
our internal policies ensure we only work with suppliers and organisations that feel the same.

Novacroft takes a zero-tolerance approach to any form of modern slavery. We are committed to trading in an
ethical manner, with integrity and transparency in all business dealings. We are committed to implementing
and enforcing effective systems and controls to safeguard against any form of modern slavery or human
trafficking taking place within our business or supply chains.

Responsibilities

Our founder and CEO, Debra Charles, alongside our senior management team, is responsible for this statement.
Our HR Team has primary and day to day responsibility for implementing this policy, monitoring its use and
effectiveness, and dealing with any queries about it and training the relevant employees. Our Head of
Governance is responsible for ensuring this policy is audited along with any associated internal control
systems and procedures to ensure they are effective in countering modern slavery.

Policy

Novacroft is determined in taking all appropriate steps to ensure that slavery or human trafficking is not taking
place. We require all new suppliers to read and sign our Supplier Code of Conduct Policy and point us to their
Modern Slavery policies. We will review the existing business and supply chains for the risks of slavery and
human trafficking.

This will include reviewing on an annual basis our procurement and human resources policies and procedures;
and training to ensure that these make clear Novacroft’s policy of zero-tolerance to any form of modern slavery
and that all employees, contractors and partners understand the appropriate mechanisms to report concerns
relating to modern slavery or human trafficking.

Novacroft’s policies and procedures include but are not limited to:

● Equal Opportunities Policy
● Company Code of Conduct Policy
● Right to Work Policy
● Human Rights Policy
● Health & Safety Policy
● Recruitment & Selection Policy
● Whistleblowing Policy
● Grievance Procedures
● Supplier Code of Conduct Policy
● Supplier management & review process

We will share this document on our webpage. We will also communicate the statement and the appropriate
mechanisms to report concerns relating to modern slavery or human trafficking on our intranet which is our
colleague communication forum.

Novacroft will not knowingly support or deal with any business involved in slavery or human trafficking.

Supply Chain

Novacroft prides itself on operating a zero-tolerance policy towards Slavery and Human Trafficking. All
employees that are responsible for procuring external goods and services are dedicated to ensuring that our
suppliers always adhere to the same ethos and will request evidence that they comply with the Modern
Slavery Act 2015.

All team members listed above are required to establish that they are dealing with trusted suppliers and to
identify and discuss the potential risks related with any new supply chains and ensure that all new suppliers
complete new supplier registration forms and agree to and sign the supplier code of conduct policy.

A copy of this statement will be provided to all businesses/entities within the Novacroft supply chain.
Novacroft suppliers, business partners and their supply chains may never engage in any activity prohibited
under the Modern Slavery Act 2015. If they are found to be or suspected to be in any way in breach, Novacroft
reserves that right to impose corrective measures up to and termination of any agreement in place between
that party and Novacroft.

Recruitment and Onboarding Practices 

Novacroft operates rigorous onboarding practices, which are audited regularly, to ensure that all employees
have the right to work in the UK. Our recruitment methods are continually reviewed to ensure transparency,
consistency and compliance with our obligations in law. We are committed to working with our managers to
develop robust talent acquisition processes which will include compliance and adherence to this policy.

Assessing Risk and Measuring the Effectiveness of this Policy

Novacroft undertakes to audit the above mentioned policies and procedures at least annually to ensure that
Novacroft and our supply chain are compliant with the Modern Slavery Act 2015 and that we have in place
measures to identify and prevent any form of Modern Slavery.

This policy has been published internally and on our website and will be reviewed in March 2023.

Our intention is to ensure that there is no modern slavery in our business or any of our supply chains. Our
ambition is to demonstrate that this is the case by implementing our commitments and continually reviewing
our procurement activities, supply chain and business partnerships and by continuing to increase the rigour in
our supply chain due diligence processes. Our supplier management and review process outlines how we
review our supply chain and what to do with non-conforming suppliers.

Our risk management process which is aligned to ISO 31000, provides us with the steps to effectively assess,
evaluate and treat risk to an acceptable level.

Novacroft has set up a monthly risk review forum that senior management attend to review the status of risks
and their mitigation. Any Modern Slavery or human trafficking risks will be managed by this forum.

Key Performance Indicators

In addition to producing the annual statement, Novacroft is committed to:

  • Identifying and addressing any areas of high risk (score 15 – 25) in our supply chain.
  • Provide training on issues relating to slavery and human trafficking for 100% of employees who are
    involved in the supply chain for example our Performance Delivery, Human Resources and Finance
    teams.
  • Carrying out regular audits to ensure that:
    • All our employees are paid at least the National minimum wage and have the right to work
      in the UK.
    • 100% of our critical suppliers have agreed and signed our supplier code of conduct policy.
  • Ensuring that all commercial agreements going forward include an obligation on our suppliers to
    operate in accordance with the Modern Slavery Act 2015 and to ensure that any of their suppliers
    and sub-contractors also operate in accordance with the Act.
  • Appointing a named individual to oversee the compliance with the Modern Slavery Act 2015. This
    person is Carl McLaughlin, Head of Human Resources.

Reporting 

Should any employee, business partner or other party have any concerns in regard to a breach of our policy, the
legislation or a likely risk of a breach they must inform the HR Department by emailing hr@novacroft.com.
Employees can also report concerns via the Whistleblowing or Grievance Policy.

Published: 21st February 2022