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Statement made pursuant to section 54 of the Modern Slavery Act 2015

39D Services is committed to the highest level of ethical standards and has a zero-tolerance policy towards modern slavery and human trafficking. We are committed to acting ethically and with integrity in all business dealings and to taking steps to ensure that modern slavery and human trafficking do not exist in any part of our business or supply chains, and to continually improving our practices to combat these crimes.

Due diligence process, risk assessment and steps taken

Overall, the nature of 39D Services’s business means that the risk of modern slavery and human trafficking in our directly managed business activities and the first line of our supply chain is relatively low. We have reviewed our operations to identify areas where there could be a risk of modern slavery within our business or within our supply chain and considered what policies and safeguards we have in place to prevent this.

Our business

39D Services employs circa 10 staff, all within the UK. At 39D Services our recruitment processes are designed and managed to ensure that all prospective employees are legally entitled to work in the UK. We comply with national minimum wage legislation, are committed to upholding the highest standard of employment practices, and have appropriate HR policies in place which staff can use to raise any concerns, including a Grievance Policy and Whistle-blowing Policy.

Our supply chain

39D Services purchases a range of goods and services with third-party suppliers, the overwhelming majority from Tier 1 telecommunications companies and 39D Services has a relatively small supplier footprint with circa 50 suppliers used in the 2019-20 financial year. We have 5 broad categories which cover the bulk of our supply chain:

  • Telecommunications Networks and Operators
  • ICT – hardware and software suppliers
  • Business support suppliers;
  • Property and facilities management suppliers
  • People and professional services suppliers

Due to the robust complaint controls 39D Services has in place, we believe that the risk of modern slavery in our supply chain is relatively low. However, 39D Services recognises the potential risks inherent in the supply chain of goods and services and is committed to upholding the Chartered Institute of Procurement and Supply Ethical Code of Conduct which requires due diligence to be undertaken on appropriate supplier relationships in relation to forced labour and other human rights abuses. If 39D Services were to become aware of modern slavery or human trafficking in the business or supply chain of any of its suppliers, we would review our rights to cancel the relevant contract/s and notify the appropriate authorities.

Further steps

39D Services is committed to better understanding our supply chains and working towards greater transparency and responsibility towards people working within them. During 2019-2020, 39D Services will:

Make relevant staff aware of the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking, either within our own business or our supply chain; Ensure that the Modern Slavery Act 2015 is referred to and consideration of the modern slavery risks and steps for prevention are added to relevant 39D Services policies.

Include a mandatory requirement in new 39D Services invitations to tender, where appropriate and proportionate, that potential suppliers must declare that they (and any sub-contractors) are compliant with the Modern Slavery Act 2015, will implement appropriate controls to prevent modern slavery, and must notify 39D Services immediately if they become aware of any instances of modern slavery within their own business or supply chain; and Include the right in 39D Services standard contract terms and conditions to terminate a contract with immediate effect if a supplier is found to be deliberately using or otherwise benefiting from modern slavery, and to oblige any supplier using a sub-contractor, or another third party, practicing modern slavery or benefiting from it, to immediately cancel that sub-contract.

Matthew Southgate - Founder

 
     
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Our mailing address is:
39D Services
Runway House
North Weald Bassett
Epping, Essex CM16 6HR
United Kingdom

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