Modern Slavery Act

Policy Statement

We are committed to improving our practices to combat slavery and human trafficking and this is reflected in our Code of Conduct which highlights the Board’s commitment to take seriously our responsibility to help prevent the crime of modern slavery and human trafficking across our own business as well as those of our partners and suppliers.

Pytronot and companies associated with Davka Group reviewed its obligations and the steps taken in the past financial year ensuring we sustain the best possible governance and oversight provisions for ensuring no modern slavery or human trafficking takes place anywhere in our supply chain and services processes.

Pytronot and companies associated with Davka Group takes the ongoing issue of modern slavery, human trafficking, forced and bonded labour very seriously and is committed to the global effort to combat it. We continue to ensure our products, services, and employment practices — and those of our customers — uphold these principles.

We are completely aware of the potential risks emerging from the abuse of services facilitating the processing of salary payments and employment benefits which, if penetrated by ‘bad actors’, can be deployed for the purposes of modern slavery including forced labour, child labour, illegal restraint, human trafficking, migrant smuggling, and extortion. We are conscious of our duty to detect, prevent, and report the associated predicate offences of corruption, bribery, and theft of a victim’s wage or employment benefits, and understand that this demonstrates our commitment to the elimination of humanitarian offences, money laundering, and other types of financial crime.

We have extended the scope of our policies, principles, and code of practice to ensure our supply chain subscribes to our rigorous standards. We encourage commitment to the Financial Action Task Force (FATF) Recommendations, the International Labour Organisation’s Declaration on Fundamental Principles and Rights of Work, and the United Nations Convention Against Corruption.

We don’t employ children, nor do we confiscate employee identification documents. We don’t permit compulsory overtime, nor do we allow worker-paid recruitment fees, as we deem this to be bribery and corruption.

We uphold people rights to have the freedom to terminate their employment with us, enjoy freedom of movement, and freedom of association. We therefore do not prevent any employee from joining any trade union. Working practices are also designed with the welfare of our employees in mind, by ensuring their physical, mental, and emotional wellbeing is maintained and free from any threats of violence, harassment, and intimidation. We prohibit all forms of discrimination and promote equity, diversity, and inclusion within the workplace because everyone matters.

Risk Assessment

Pytronot and companies associated with Davka Group operates group risk management practices with localised and group-level reporting routes governed by a risk management system consisting of a framework, policy, and standard operating procedures. We apply a ‘principles and outcomes’ approach in risk management practices, which is underpinned by our corporate governance framework. Both the corporate governance and risk management frameworks are matters reserved for the Board and are reviewed annually for adequacy. All our management systems integrate with each other within our group GRC Manual, forming a dynamic suite of collateral informing our employees on best practices, influencing behaviours in our ways of working, and setting minimum standards of compliance.

Within our financial crime prevention management system, our financial crimes framework is the primary document where modern slavery and human trafficking are governed and managed. Due to its regulatory nature, we adopt a risk-based approach in the way we operationalise requirements. Modern slavery and human trafficking can be very hard to detect, especially when efforts are being made to hide this type of criminal and unethical activity. We proactively acknowledge emerging threats and adapt our controls environment to keep pace with new threats and trends through formalised, documented risk management processes.

We are fully aware of how to recognise signs of modern slavery and human trafficking through our internal controls, which would trigger further investigation if identified. Our systems and controls ecosystem is under continual development, with collaboration between the skilled teams delivering our services and those maintaining compliance oversight and independent assurance over our supply chain.

Due diligence

We have reviewed the adequacy of our governance structure in accordance with our document management processes and are satisfied our commitment, policy, and operational provisions meet requirements.

We have continued to develop our education and awareness programme, aligning the messaging to the specific nature of our business, as well as to modern slavery and human trafficking in the current context. Whilst the risk exposures are low due to the nature of our business and core services, we are committed to making sure our employees stay alert and know what to do, should they identify any suspicious activity.

Our control objectives are mapped against risks and designed to classify the control type, outline the purpose of the control and why it exists, and how to perform the control to ensure signs of modern slavery and human trafficking are detected, prevented, and reported. We continue raising awareness within the wider community through blogs on modern slavery.

Supply chain management enhancements

We appointed a dedicated independent resource within the governance, risk, and compliance function to set up and deliver a fully comprehensive, auditable supplier assurance programme. The segregation of duties from sustainable procurement practices has enabled appropriate oversight and governance over our supply chain, separate to commercial activity.

Our programme incorporates assessments on modern slavery, human trafficking, and child labour practices, as well as supplier management commitments to their eradication, should they occur. In the interim period, while we digitise our supply chain mapping across jurisdictions, we have developed the blueprint of our supply chain to understand where we may have modern slavery, human trafficking, and child labour vulnerabilities. We confirm that we have selected suppliers to lower such risk exposures and have no concerns to report.