Modern Slavery Policy

1. Introduction

Pedwar Ltd. is committed to combating modern slavery and human trafficking in all its business dealings and relationships. This policy outlines our dedication to acting ethically and with integrity in all our business operations and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere within our company or our supply chain.

2. Definitions

For the purposes of this policy:

• Modern slavery encompasses slavery, servitude, forced and compulsory labour, and human trafficking.
• Human trafficking involves recruiting, harbouring, or transporting people into a situation of exploitation through the use of violence, deception, or coercion and forcing them to work against their will.

3. Scope

This policy applies to all persons working for or on behalf of Pedwar Ltd. in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

4. Company Structure and Supply Chains

Pedwar Ltd. is a web design and development company based in Swansea, offering web hosting services. Our primary operations involve digital services, and our supply chains include:

• Technology providers
• Software suppliers
• Hosting service providers
• Office equipment and supplies vendors

While the risk of modern slavery in our immediate operations is low, we recognise that our supply chains may extend into sectors and regions with higher risks.

5. Risk Assessment

We have conducted a risk assessment of our operations and supply chains. Areas of potential risk include:

• Third-party software development services
• Hardware manufacturing for our hosting services
• Cleaning and maintenance services for our offices

We are committed to continually assessing and addressing these risks.

6. Due Diligence Processes

To mitigate the risk of modern slavery and human trafficking in our operations and supply chains, we:

• Conduct thorough vetting of suppliers and partners
• Include anti-slavery clauses in our contracts
• Regularly audit our supply chains
• Encourage transparency and maintain open communication with our suppliers

7. Training and Awareness

Pedwar Ltd. is committed to ensuring that all staff understand the risks of modern slavery and human trafficking in our operations and supply chains. We provide:

• Regular training sessions for all employees
• Specific training for staff involved in procurement and supplier management
• Information on modern slavery risks in our employee handbook

8. Reporting Concerns

We encourage all employees, customers, and suppliers to report any suspicions of modern slavery in any part of our business or supply chains. We provide:

• A confidential whistleblowing hotline
• An email address for reporting concerns: [email protected]
• Protection for whistleblowers as outlined in our Whistleblowing Policy

9. Monitoring and Review

We will continually evaluate the effectiveness of our anti-slavery measures by:

• Regularly reviewing this policy and our risk assessment
• Conducting internal audits
• Seeking feedback from employees and suppliers

This policy will be reviewed annually to ensure its continuing suitability, adequacy, and effectiveness.

10. Approval and Sign-off

This Modern Slavery Policy has been approved by the Director of Pedwar Ltd. It demonstrates our commitment to combating modern slavery and human trafficking and will be made available on our website.