Organisational structure and Supply Chains

Digital Transformation Advisory Limited has business operations in the United Kingdom, supplying our clients with advisory services from staff in the UK and partnering with select partners for remote technology staff in a resource argumentation or technology solution delivery model. We operate in the financial services and technology sectors.  Our suppliers in remote locations, India and Eastern Europe are risk assessed in relation to slavery or human trafficking, is reduced by ensuring they provide for each candidate: 

• Ensuring all staff provided have residency rights for the country
• Conducting a check of education history
• Confirmation of recent employment history
• Background criminal checks with the relevant authorities in the country

Performance indicators

We have reviewed our key performance indicators (KPIs) to align with this policy. As a result, we are:

• Requiring all staff/ supply chain managers/HR professionals to have completed training on modern slavery within their probation period.
• Have developed a system for supply chain verification, whereby we evaluate potential suppliers before they enter the supply chain.

Responsibility

Responsibility for our anti-slavery initiatives is as follows

• Policies:
  Legal and CEO develop ad review policies and ensure they are followed.
• Risk assessments:
  Suppliers of third-party staff are the highest risk and both the suppliers and the staff they provide as assessed and evidenced during the selection and onboarding process.
• Training:
  HR and managers are provided with training material and reviewed during induction and again when assigned to supplier assessment and staff interviewing. The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company's training covers:
  
  - How to identify the signs of slavery and human trafficking.
  - What initial steps should be taken if slavery or human trafficking is suspected.
  - How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
  - What external help is available. What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company's supply chain.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy:
  We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can complete our confidential disclosure form.
• Employee code of conduct:
  Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier/Procurement code of conduct:
  We are committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of our supplier code of conduct will lead to the termination of the business relationship.
• Recruitment/Agency workers policy:
  We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency it is using before accepting workers from that agency.