Introduction

This Modern Slavery Policy Statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) relating to Transparency in Supply Chains.
The Change Mavericks Ltd (“Change Mavericks”) recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking and indeed takes a zero-tolerance approach to non-compliance with the Act in any part of its business or its supply chain.
This statement sets out the steps Change Mavericks will continue to take to address the risk of slavery and human trafficking within its operations and supply chain.

Our business

Change Mavericks’s business involves consulting on technology matters to businesses large and small across any sector.

Our governance for modern slavery

The Change Mavericks Board has overall responsibility in respect of the approach to Modern Day Slavery.
The Change Mavericks Board has established a Modern Slavery Working Group to review the approach to Modern Slavery, co-ordinate and monitor the activities of the business in this regard.

Our policy on slavery and human trafficking

Change Mavericks is fully committed to reducing the risk of modern slavery or human trafficking occurring in its supply chain or in any part of its business with a zero tolerance for non-compliance.
This Policy applies to all Change Mavericks employees and associates as well as, suppliers and subcontractors, who must ensure that both their businesses and supply chains worldwide comply with this Policy.
This Policy reflects that commitment to acting ethically and with integrity in all business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chain. Suppliers and subcontractors must comply and act in accordance with this Policy.
Change Mavericks has an effective grievance and whistle blowing process and policy in place to manage and investigate any concerns within the business or the supply chain.

Our supply Chains

Change Mavericks’s supply chains include:

• Value Added Resellers

• Subcontractors and other service providers

• Suppliers of contingent labour

• Manufacturers and suppliers of goods and materials

All procurement of services and supplies is undertaken by professional procurement specialists. The intention is to build and maintain long term sustainable relationships with suppliers encouraging collaborative working and exchange of innovative and good industry practices.

The supply chain includes approximately 100 suppliers of varying size and expertise.

The onboarding process includes verification of:

• No forced labour or human trafficking is practiced, and employment is freely chosen.

• Working conditions are safe.

• Working hours are not excessive.

• Compliance with National Minimum Wage

• No child will be exploited.

• No harsh, cruel, or degrading practices are allowed.

• No discrimination is practiced.

A failure to satisfy the above criteria is an absolute bar to pre-qualification as a supplier to Change Mavericks.

Certain areas require an enhanced level of diligence and Change Mavericks has taken a category specific approach, assessing the risk of Modern Slavery occurring within its business notwithstanding whether the deliverable is outsourced or delivered in-house.

The emphasis can therefore be focused on those categories considered most at risk.

The following procurement categories are considered to be of highest risk of Modern Slavery occurring:

• Recruitment

• Cleaning Supplies and Services

• Provision of Temporary Staff

Recruitment & Training

Change Mavericks undertakes pre-employment screening that includes identity checks and confirmation of entitlement to work in the UK for all employees prior to commencing employment. This is supported by Change Mavericks’s Right to Work Policy and Security and Vetting Policy.

As part of the onboarding process, on joining Change Mavericks each employee is given an overview of the essential policies and information in relation to those policies, procedures, and other matters such as whistle blowing.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Change Mavericks’ slavery and human trafficking statement for the financial year ending 31 December 2022.

The statement has been approved by the Board of Directors of The Change Mavericks Ltd.