Modern Slavery and Human Trafficking Statement

This statement applies to iPortalis Aggregation (the Organisation) and refers to the financial year 2022.

The main activity of the Organisation is software development. The labour supplied by the Organisation in pursuance of its operation is carried out in UK and Malaysia.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

The Organisation 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 restriction placed on freedom of movement

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practise in relation to its labour
force and, additional, its supply chains.

The Organisation 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 the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in  relation to its responsibilities under relevant employment legislation in United Kingdom or Malaysia and in many cases exceeds those minimums in relation to its employees.

1.1 Our Supply Chain

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.

Our supply chains are limited, and we procure goods and services from a restricted range of UK and overseas suppliers.

1.2 Our Policies in Relation to the Modern Slavery Act 2015

The following policies are available to all staff through the iPortalis intranet and staff handbook:

• Code of conduct- our code encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
• Whistleblowing Policy - we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation.

1.3 Embedding The Principles

We will continue to embed the principles through:

• providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
• ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
• ensuring that consideration of the modern slavery risks and prevention are added to the
  iPortalis policy review process as an employer and procurer of goods and services
• making sure iPortalis procurement strategies include references to modern slavery and
  human trafficking
• continuing to take action to embed a zero-tolerance attitude towards modern slavery
• ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.