Modern Slavery and Human Trafficking Policy

Introduction

Modern slavery and human trafficking is a unfortunately still a global problem, even in 2021. It is estimated that over 40 million people worldwide are subjected to some form of modern slavery and at cloudabove we feel that we all have a responsibility to ensure that our daily work and choices do not support these practices and to report any suspected activity that is believed to be using them. At cloudabove (SWBROADBAND Ltd) we are committed to eliminating any possible use of modern slavery from our business and supply chain.

Our Organisation

At cloudabove, we provide exemplary web hosting services in the UK and further afield. We are an SME operating from Cornwall, UK. Our annual turnover does not meet the legal requirement to issue this statement, however we feel that it is important for all businesses to take responsibility and act to prevent modern slavery and human trafficking.

The company's Managing Director, Ryan Devonshire, is ultimately responsible for ensuring that the company does not breach this policy, however all staff at cloudabove have a responsibility to assist in this by adhering to company ethics and reporting any suspected breaches of this policy.

Policy

cloudabove has a zero tolerance approach to modern slavery in any form and we are committed to acting ethically and with integrity in all of our business dealings. We expect the same from our suppliers and contractors.

cloudabove prohibits the use of forced, compulsory, excessive and trafficked labour in our business directly and supply chain and will not use the services of any company or supplier that is suspected of or proven to be in breach of this.

Employees of cloudabove are to be aware of the signs of modern salvery and human trafficking and know how to report this. Managers are to be trained to further identify this along with the higher risk areas of employment and how to escalate reports and to which authorities.

Employees are encouraged to report any suspicions of modern slavery in any part of our business or supply chain and will never face repercussions for doing so where such reports are made in good faith.

As a smaller business, we feel that is important for our employees to know where to turn if they believe that the managers/MD are failing to act on reports of modern slavery, or are in breach of this policy themselves. If this is the case, employees can call the Modern Slavery Helpline on 08000 121 700 or the police on 101. In an emergency always call 999.

Due Diligence

To identify and mitigate the risks of engaging the services of companies that use modern slavery practices, we:

Build long standing relationships with suppliers wherever possible and make clear our expectations of business ethics
Research businesses/individuals already in our supply chain, and those we intend to employ the services of, with regards to company ethics including modern slavery policy/statements
Periodically audit our suppliers to ensure that they meet and uphold our ethical standards
Provide basic training to all staff of the high risk areas of modern slavery, identify common warning signs and how to report concerns
Have in place systems for reporting concerns and protections for whistleblowers

Risk

Our industry is generally considered low risk for the involvement of modern slavery, however consideration must be given to the manufacture of the products that we use and other services that we may employ. We believe that we are not using or supporting modern slavery or human trafficking in our business.