The UK Government enacted the Modern Slavery Act 2015 (the Act) in order to better tackle the crimes of modern slavery and human trafficking, in all of their forms. As well as consolidating the criminal offences relating to modern slavery and human trafficking, the Act also introduced a requirement for each business to publish an annual statement setting out the steps taken by the business to ensure that modern slavery and human trafficking are not taking place in the business or supply chains.
This statement sets out the steps taken by Armakuni during the financial year ending 30 June 2021 to prevent slavery and human trafficking from taking place in any part of the business, including the supply chain, and the ways the business has sought to minimise the risks of any association with practices which undermine the principles of safety for employees, customers and business partners.
About Armakuni and Organisational Structure
This statement covers the activities of Armakuni Ltd.
The main activity carried out by Armakuni is the provision of consultancy services to businesses across the world. Employees work either remotely from home or are on projects based on client sites. Armakuni has a flat structure which is controlled by a board of directors and has 47 employees.
Definitions
Armakuni considers that modern slavery encompasses:
human trafficking
forced work, through mental or physical threat
being owned or controlled by an employer through mental or physical abuse of the threat of abuse
being dehumanised, treated as a commodity or being bought or sold as property
being physically constrained or to have restrictions placed on freedom of movement
Commitment
Armakuni acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Armakuni understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
Armakuni is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Armakuni does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to Armakuni in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Armakuni strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
Supply Chains
As a provider of professional consultancy services, Armakuni has a small supply chain; our main suppliers being IT services and equipment. The majority of our supply chain is based in the UK, and the occasions on which we employ suppliers from high risk countries are minimal.
Potential Exposure
In general, Armakuni considers its exposure to slavery/human trafficking to be relatively limited. Armakuni realises that slavery and human trafficking can occur in many forms such as forced labour, child labour, domestic servitude, sex trafficking and workplace abuse, but due to the specific nature of the business, it considers that there is a low risk of these sorts of practices occurring in our business and supply chain. Nevertheless, we are committed to preventing these practices from occurring within both our business and supply chain. This is further mitigated by Armakuni’s culture and ethical standards along with our policies listed below.
Relevant Principles and Policies
Armakuni has developed a culture of open communication where all individuals can feel safe to discuss their opinions, views and/or concerns without fear of reprisal, subsequent discrimination or disadvantage. We believe this approach helps us to maintain a culture built on trust and openness under which the aiding, abetting, counselling or procurement of forced labour and human trafficking would not be tolerated under any circumstances.
Our Whistleblowing Policy provides support and guidance to any individual who wishes to report any concerns related to the direct activities, or the supply chains of Armakuni.
Our Employee Handbook and the associated policies make clear to employees the high standards of conduct and ethical behaviour expected of them when representing Armakuni.
Our extensive recruitment process that includes verifying an individual’s right to work in the United Kingdom, appropriate documentation in support of the employment relationship and 100% of our employees being paid above the National Living Wage show a commitment to avoiding labour exploitation within our own business.
We use only specified, reputable employment agencies to assist in recruiting employees and contractors and seek to verify the practices of each of these agencies before a contract is agreed.
Due Diligence/Managing Risk
Armakuni manages potential risks through appropriate business practices including project management and procurement processes which includes regular monitoring of supplier performance.
Armakuni does not wish to be associated with any organisation that either has or is found to be involved with either human trafficking or modern slavery and has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
If we were to find evidence that one of our suppliers had failed to comply with the Modern Slavery Act 2015 we would require that supplier to remedy such non-compliance and if we did not see substantial improvement in the way their business was conducted we would terminate our relationship with them.
Training
Given our view that Aramkuni’s exposure to modern slavery risk continues to be limited, we consider our existing due diligence and other processes to be sufficient and appropriate to manage this level of risk. However, should circumstances arise which we consider may be particularly high risk, appropriate training will be developed and targeted at relevant staff members. This approach will be reviewed periodically by senior management.
Approval
This statement has been approved by the executive team who will review and update it on an annual basis.
End
February 2023