UK Modern Slavery Act Statement Financial Year 2021/22
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and covers our financial year to 2021/22. It details the steps that STAR Index has taken and will implement in our upcoming year to tackle modern slavery and human trafficking within our business and supply chains.
Organisation Structure and Supply Chains
STAR Index is a leading technology and consulting businesses operating in sectors such as global risk and compliance management and marketing services. As part of STAR Index we employ c.60 members of staff across locations in the UK and India, all on full and part-time contracts, honouring EU minimum wage and working time directives. We have over 50 core Tier 1 suppliers of goods and services such as IT, utilities and inputs.
Policies & Procedures
At STAR Index we passionately believe in upholding the integrity of supply chains, in fact this is core to the operations of our businesses, who are active in the space of ESG, Sustainability and tackling issues such as Modern Slavery. We are therefore committed to living these values ourselves, with a priority of eradicating any forms of slavery at the heart of our drive for integrity. STAR Index supports the basic and fundamental human rights of all individuals and does not condone any form of modern slavery, human trafficking, child labour, or exploitation in any form within its business and supply chains.
We adopt a zero-tolerance policy to any human rights abuses and we have worked extensively with NGOs such as Unseen UK to build capacity and ensure our employees understand and adhere to this policy.
We are therefore committed to tackling modern slavery and forced labour through a continuous improvement approach. We have adopted the core 9 principles of the Ethical Trading Initiative (ETI) Base Code (https://www.ethicaltrade.org/eti-base-code) and the 8 core conventions of the International Labour Organisation (ILO) (https://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-and-recommendations/lang–en/index.htm) to allow us to hopefully identify and mitigate the risk of modern slavery in our own organisations, and those of our suppliers and sub-contractors.
Due Diligence Processes
We have appointed our first ‘Social Compliance Officer’ at Director level within the business (Rick Sanderson FIFST). During this financial year we will be initiating our own Ethical Trading Policy and a Supplier and Partner Code of Practice. This will be supported by an initial Self-Assessment Questionnaire (SAQ), which will require robust evidence against our core standards and those set out in the ETI and ILO Base Codes, with ongoing monitoring.
This information and commitment will be required retrospectively of all existing suppliers, and mandatory as part of our new vendor process hence forth. In addition, we will hold on file and scrutinise all suppliers of goods and services to STAR Index that are required to publish a Modern Slavery Act 2015 Statement, i.e. all those above the current threshold of £36m in turnover with operating Head Offices within the UK, and any emerging legislation applicable to non -UK supply chains.
Risk Assessment and Management
Recognising that the risk of modern slavery is always present we will ensure that we review our internal strategic and operational approach annually.
We have carried out an initial risk assessment of our core Tier 1 supplier base and concluded that our exposure to issues around Modern Slavery are relatively low. However, we recognise that our role is to safeguard against exposure to this issue and play our part in its eradication.
We have analysed our FY20/21 annual spend and drawn up a target list of the Top 10 by turnover. This represents a mix of large global companies with compliant Modern Slavery Act Statements and published programs, and smaller to medium size UK businesses sub- £36m turnover, who in the main do not have statements.
We have classified those without a statement as ‘At Risk’, and we will be working with these businesses with a request to complete a Modern Slavery SAQ issued by STAR Index. This will be completed in the first half of FY21/22. We also recognise that risks can be ‘hidden’ in our supply chains and we commit to working on a program to map those we work with both across and down our supply chains. Where instances of modern slavery are uncovered, we will work to remediate effectively and ensure any workers are appropriately safeguarded and protected.
We have also established our own ESG scores and targets using our STAR Index platform, allowing us to soon set net-zero targets and wider Sustainability targets and goals.
Transparency in Supply Chains
We understand that the risks of Modern Slavery are just as high beyond our immediate supply base, and as such we be utilising our own platform www.supplychainmapper.com, an online supply chain mapping toolkit, for identified “at risk” suppliers to STAR Index, providing a FREE tool for them to attempt to map their supply chains.
The results of these efforts will be reported in next year’s Modern Slavery Act statement, FY22/23.
Key Performance Indicators to Measure Effectiveness of Steps Being Taken
We commit to tracking and maintain progress against the following key criteria:
Significant Tier 1 suppliers MSA Statements Tracked and Scrutinised
Supply Chain Maps instigated for ‘At-Risk’ Suppliers
All staff trained to build capacity and spot the signs of Modern Slavery Training on modern slavery and trafficking
We are committed to training and raising awareness of our people and those who work for us so that we can better spot the signs of modern slavery and forced labour.
Working with leading NGO Unseen UK (https://www.unseenuk.org/) we have co-developed an e-learning platform to set the scene and offer guidance and tools to combat the issues . During the first half of this financial year this training will be given to all members of staff. This training will enable our employees to better understand and recognise modern slavery risks that might occur within our business and supply chains and informs them of the appropriate actions if such issues are discovered.
We will also be providing an impartial whistle-blowing facility. Completion of these front line remediations will be monitored by our Human Resources officer. The welfare of our people is paramount, and we are committed to ensuring our policies, practices and procedures reflect this and all appropriate employment regulations and legislation are fully adhered to.
This statement is made pursuant to section 54(1) of the Act, has been approved by the Board of Directors of STAR Index and will be updated annually in line with the Modern Slavery Act’s reporting requirements.
Managing Director – STAR Index