The Modern Slavery Act 2015 (the “Act”) creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking.
This is the Modern Slavery and Human Trafficking Statement of the Maintel Group, consisting of Maintel Holdings Plc and its subsidiaries. It is made pursuant to s.54(1) of the Act and has been adopted by all companies in the Maintel Group as their respective slavery and human trafficking statement for the financial year ending 31 December 2016. In accordance with the requirements of the Act, the statement will be reviewed, updated and published annually and will therefore be reviewed and updated at the end of the 2017 financial year.
In accordance with the Act, this Statement is published on Maintel’s website, www.maintel.co.uk.
Our business involves the supply, configuration and support of telecommunications solutions worldwide and we had pro forma Group revenues of around £100m in 2016, incorporating approximate annualised revenues of Azzurri Communications Limited, which was acquired during the year. We have around 650 employees, operating from 7 offices throughout the UK and one in the Republic of Ireland. Our supply chain therefore involves the sourcing, acquisition and supply of telecommunications services, software and hardware. It is far reaching and complex in nature, incorporating around 900 suppliers, most of which in turn will have their own suppliers.
The vast majority of our purchases of goods and services are globally recognised brands that are supplied through distribution or reseller channels within the UK; however many of the goods in particular are likely to have been produced elsewhere with some of these countries potentially posing a greater risk than that present in the UK. Some suppliers, however, are local UK companies, and their own employment policies are also taken into account.
Respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility. As customers, however, we play an active role in monitoring them to ensure that they operate in an ethical and transparent manner.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or elsewhere in our business. Should Maintel be made aware of any such practice it would act immediately and decisively to highlight and remedy it. Our Anti-slavery position reflects our commitment to acting ethically and with integrity in all of our business relationships. This is supported by our policies on bribery and corruption, and whistleblowing.
The directors of Maintel believe that the risk of it or any of its suppliers not adhering to the Act is small, and so it has not actively audited this position during 2016, but has begun to in January 2017, adopting the following processes.
As part of our initiative to identify and mitigate risk we endeavour to:
In practice, this entails focussing on the larger suppliers to the Maintel Group, together with those which we consider to have inherent risk.
Maintel relies initially on desk-based research to verify that its suppliers are themselves adhering to the provisions of the Act. It does so by:
The Group has also developed standard contractual wording for inclusion in its supplier agreements where feasible to do so, and has produced a Supplier Code of Conduct which is made available to all suppliers and which sets out minimum requirements for our suppliers.
Our Modern Slavery Act Statement and Policy will continue to be reviewed and developed as part of the Company’s regular Corporate Governance agenda.
This Statement has been approved by the board of Maintel Holdings Plc.
26 January 2017