Modern Slavery Statement

This statement is made in accordance with s.54 of the Modern Slavery Act 2015. It sets out the steps that Cybercentry Limited has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within our organisation, our partners, our sub-contractors or supply chain. 

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Cybercentry Limited has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to ensuring effective systems and controls are in place to safeguard against any form of modern slavery taking place within the organisation or supply chain. 

Our business 

Cybercentry Limited is an Information and Communications company, providing Cyber Security, Information Security and Data Protection services. Cybercentry Limited provide a range of services to businesses and partners. 

In addition to Cybercentry Limited’s responsibilities as an employer, it is committed under s.52 of the Modern Slavery Act 2015 to notify the Secretary of State of suspected victims of slavery or human trafficking. Cybercentry Limited is located in Cheltenham. Cheltenham having a number of bus stations and several train stations meaning there are many transport and access routes for consideration in relation to modern slavery and human trafficking. 

Our policies 

Cybercentry Limited reviews its policies and procedures on a regular basis and operates several internal policies to ensure we are conducting business in an ethical and transparent manner and in compliance with the Modern Slavery Act. These include: 

• The Modern Slavery Guidance sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help. 
• We operate a robust ‘Safer Recruitment and Selection Policy’, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Cybercentry Limited is responsible for ensuring all procurement activity complies with Cybercentry Limited’s ‘Contract Procedure Rules’ and wider ‘Public Contract Regulations 2015’.
• We operate a ‘Whistleblowing Policy’ so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
• Our ‘Code of Conduct’ explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act. 

Our suppliers 

Cybercentry Limited operates a supplier policy and maintains a database of registered suppliers as well as a corporate contract register. We conduct financial due diligence on all suppliers before allowing them to become a contractual supplier. This may include an online search to ensure that a particular organisation has never been convicted of offences relating to modern slavery [and on-site audits which include a review of working conditions]. Our anti-slavery policy forms part of our contract with suppliers and they are required to confirm that no part of their business operations contradicts this policy. 

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that: 

• They comply with the Modern Slavery Act 2015: Requirements under Modern Slavery Act 2015.
• They are a relevant commercial organisation as defined by section 54 ("Transparency in supply chains etc.") of the Modern Slavery Act 2015 ("the Act"). 
• If they answer yes to the previous question, are they compliant with the annual reporting requirements contained within section 54 of the Act 2015. 

Next steps 

We will further embed the importance of the Modern Slavery Act into our business and supply chain procedures, ensuring that our activities and that of our suppliers are committed to complying with the requirements of the Act. We will continue to monitor and audit our policies and procedures to make amendments and update staff where necessary. 

Cybercentry Limited also commits to: 

• Deliver a programme of training and awareness raising for the workforce and third sector organisations.
• Promoting national campaigns to help raise awareness of modern slavery and human trafficking. 
• Reviewing, and refreshing where applicable, the adult safeguarding referral pathway to better identify and support potential victims of modern slavery and human trafficking. 
  
• Enhance data and intelligence gathering across partners to help identity and support potential victims, as well as inform disruption activities. 

This statement is made under section 54(1) of the Modern Slavery Act 2015 for the financial year ending 5th April 2024. 

Approval for this statement 

This statement was approved by 

Mr. Leigh Cronian 

Managing Director

Cybercentry Limited

20:14 06/04/2024