As an organisation that helps our customers create a safer, more sustainable world, Alcumus is continuously taking steps to combat modern slavery and human trafficking and is committed to meeting our obligations under the Modern Slavery Act 2015. This statement applies to all companies listed under the section ‘Our Business’. We take a zero-tolerance approach to non-ethical practices and are committed to acting professionally, fairly, and with integrity in all our business dealings and supply chain relationships, wherever we operate. We are committed to implementing and enforcing effective systems to uphold ethical standards which combat modern slavery and human trafficking.
Our Structure
We provide risk management and compliance services for a wide range of industry sectors and are predominantly UK focused, with operations in North America. We operate throughout the UK with our head office in Cardiff. We also have offices in North America and Lebanon ensuring that our teams comply with relevant legislation and monitor their supply chains accordingly.
Our Business
Our business provides a number of products and services to a breadth of customers, ranging from sole traders to multinational companies. Our associated legal entities providing services to our customers include:
Alcumus Holdings Limited
Alcumus SafeWorkforce Limited
Alcumus ISOQAR Limited
Alcumus SafeContractor Limited
Alcumus SafeContractor Inc. (Canadian registered company)
Cognibox Inc. (Canadian registered company)
citrusHR Limited
Planet First Limited
Alcumus offers a solution for clients to manage and mitigate any risk of modern slavery in their supply chain, through our supply chain compliance solutions.
You can read more about this in our Modern Slavery whitepaper.
Our Supply Chain
We have a primarily UK-based supply chain which includes a small number of suppliers from North America. It includes larger technology providers as well as third-party associates and consultants, SMEs, and local businesses that have the requisite technical skills and qualifications to help us deliver our services. One of our legal entities also operates a partner network that is predominantly based in India, South Africa, Serbia, and Turkey. As part of our contracting process, we require all suppliers to adhere to our code of conduct detailing our modern slavery commitments and values to uphold. Where contracting on our standard supplier terms, we expressly require strict compliance with modern slavery legislation. We are further implementing modern slavery into our supplier on-boarding process to ensure every new and current supplier has adequate statements in place to reflect the modern slavery standards we hold. Our annual review of our suppliers allows us to ensure continued compliance against these standards. Suppliers with a high controlled risk rating are subject to further audit requirements on a regular basis. The consequence of non-compliance is clear and actioned which may result in us not entering into, or terminating, relationships with suppliers.
We are also a funding partner of the Supply Chain Sustainability School (SCSS), established in 2012 to upskill organisations across the built environment supply chain. Partnership of the SCSS includes free, unlimited access to learning materials, best practice resources, and industry events – available to our employees, suppliers, and clients – with the prevention of modern slavery being a pivotal topic within the library of best-in-class information. We actively promote the use of the SCSS learning resources to our employees and suppliers to ensure they understand how to identify, prevent and address modern slavery, in all its forms. Our employees have modern slavery training material embedded within their induction process and over the last year over 150 resources from the SCSS were utilised.
Our Policies
We are committed to ensuring that there is no modern slavery, human trafficking, child or forced labour in our supply chains or in any part of our business. As part of this commitment, in addition to this statement, we have the following policies within Alcumus:
- Whistleblowing Policy;
- Code of Conduct Policy; and
- Anti-Bribery and Corruption Policy.
- Control of Suppliers Policy
These policies reflect our commitment to acting ethically and with integrity in all our business relationships. We implement and enforce effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains. As part of our internal sustainability programme, we are working to improve and strengthen our policies further and work closely with our suppliers to ensure that they are aware of and compliant with these.
In 2021, we established a partnership with the UK-based anti-slavery charity, Unseen. This collaboration has helped increase awareness of the importance of business accreditation and technology to demonstrate compliance to regulations, which actively supports the charity’s ongoing vision of working towards a world without modern slavery. You can read more about our partnership on our website and here.
Due Diligence and Training
We have procedures in place to establish, assess, and monitor areas of the potential risk of slavery and human trafficking occurring in our businesses and supply chains. We actively promote the importance of raising any concerns to staff and provide adequate protection for whistle-blowers. We have appropriate measures in place to mitigate the risk of modern slavery practices occurring within our business e.g. checking the authenticity of right to work documents.
To ensure a greater understanding of the risks of modern slavery and human trafficking in our business and supply chains, we currently have in place processes to educate our employees to recognise the risks of modern slavery in our business and supply chains. Modern slavery forms part of our induction to all new employees and specifies the content we have available for additional training. We provide the content created by the Supply Chain Sustainability School to all employees to improve their understanding and highlight their role in identifying problems to report.
Current Activity
We are utilising Planet Mark internally within the business, embarking on a group wide ESG Strategy. As part of this new Net Zero Sustainability Programme we are completing a supplier maturity assessment to understand the top tier suppliers within our supply chain at a deeper level which will allow further supplier engagement to be initiated. This will help us understand all aspects of our supplier’s ESG regulatory compliances.
Plans are in place to create a modern slavery committee dedicated to addressing concerns with our supply chain, future improvement, and producing an expanded modern slavery statement with greater practical application, evidencing our values and how they are met.
Concluding Remarks
This statement has been approved by the Dragon UK Holdco Limited Board of Directors and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Alcumus’ slavery and human trafficking statement for the current financial year in which it is written.
Tim Jackson
Chief Financial Officer, Alcumus
March 2024