Atendco Ltd is committed to ensuring that there is no slavery or human trafficking in our supply chains or any part of our business. The processes set out below reflect the organisation’s commitment to acting ethically and with integrity across the organisation.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Atendco’s slavery and human trafficking statement for the financial year ended 31 January 2021.
THE STRUCTURE, BUSINESS AND SUPPLY CHAIN OF THE ATENDCO
Structure
Atendco Ltd is a UK incorporated company.
Atendco is composed of management consultants who provide specialist digital services to organisation’s . Further information about the structure of the Atendco can be requested.
Business
Atendco operates in the Digital Sector and aims to lead the world in digital product development.
Procurement
The supply chain of the Atendco includes a small number of diverse suppliers from across the world, including suppliers of goods and services that directly support user research and product development.
In FY 20/21, the organisation’s third party spend fell into three main categories:
| Professional Services (e.g. temporary staff, consultancy) | 6% |
| IT (e.g. telecoms, hardware, software) | 6% |
| Commodities (e.g. travel, books, office supplies) | 8% |
The Atendco has supporting systems in place to identify and assess potential risk areas and to mitigate the risk of slavery and human trafficking occurring in our supply chains.
When reviewing our supply chain from a risk perspective, we consider both the types of goods and services we procure and the location we procure these from.
The Atendco requires suppliers to complete a due diligence questionnaire in respect of all contracts exceeding £100,000 (ex-VAT) in value and recommends the questionnaire for use by business areas when contracting between £25,000 and £100,000 (ex-VAT). This questionnaire includes a potential ground for rejection relating to convictions under the Modern Slavery Act 2015 and asks that suppliers confirm they comply with and have written policies and staff training in place in respect of, s54 of the Modern Slavery Act 2015.
Modern slavery requirements have been included as a Pass/Fail question in the award of all recent frameworks established to support Programmes and Products. This includes Data Consultants, Product Designers and Engineers.
For purchases under £25,000 (ex-VAT) a more limited due diligence checklist is recommended which asks suppliers to confirm there have been no convictions under the Modern Slavery Act 2015, or if there have been that appropriate steps have been taken to rectify the identified issues.
All preferred suppliers have at least an annual review and are asked to provide written confirmation that no convictions have occurred in relation to the Modern Slavery Act 2015, or if a conviction has occurred that appropriate steps have been taken to rectify the identified issues. All preferred suppliers are requested to provide their Modern Slavery Act 2015 policy statement as part of the review documentation, and an additional question has been included in the review template to identify specific actions taken to combat modern slavery during the previous twelve-month period. We expect this to prompt suppliers to improve their statements year on year.
The questionnaire and review templates can flag high risk services within our direct, centrally managed spend such Information technology equipment; and Outsourced labour (e.g. data science). They have been developed for use in preferred supplier reviews to further support the identification and management of supply chain risk. These prompt discussions with the supplier regarding the management of their onward supply chains.
The Atendco is planning to initiate further discussions with preferred suppliers in FY22/23 and develop key performance indicators to help it better assess its effectiveness at identifying and managing risks related to Modern Slavery and Human Trafficking in its operations and supply chain.
OUR POLICIES
The Atendco has a number of policies which govern our activities and aim to reduce the risks of modern slavery and human trafficking in our operations and supply chain:
MSA Policy
HR Policies
The organisation’s approach to recruitment, including specific expectations in respect of the recruitment of children is available on request.
HR guidance to recruiting departments covers the following areas:
- ID and other documents: original documents must be seen as part of the right to work and other pre-employment checks, but copies must be taken for the files and the originals handed back to the owner.
- Employment of under-18s: UK legislation on the employment of minors is set out in the guidance and departments are instructed to follow it. The guidance on right to work checks asks departments to check that dates of birth are consistent across documents and consistent with the appearance of the individual.
- Temporary staff: recruit temporary staff via external agencies – agencies are asked to confirm that they carry out the same pre-employment checks as the company.
The Atendco is committed to ensuring that people are paid appropriately for the work that they carry out. This commitment is set out in the information on pay structures.
The Atendco is in the process of becoming an accredited Living Wage employer. This means that the Atendco has committed to pay both employees, and the staff of contractors and sub-contractors who work regularly (i.e. two hours or more over eight consecutive weeks within a year) on Atendco premises in the UK at or above the Living Wage rate.
Public Interest Disclosure (Whistle-blowing) Code of Practice
The Atendco places the greatest importance on the integrity of its operations, and has in place a number of policies and procedures to address problems that may arise for its employees and students. Where there are genuine concerns about possible malpractices or improprieties that are not adequately covered by other Atendco policies or procedures, staff are encouraged to make a public interest disclosure. This code of practice therefore provides an additional means for people to raise concerns about a supply chain or an individual who may be at risk. Atendco has begun a process of reviewing this Code and notes that while this process is underway should anyone outside the Atendco wish to raise concerns regarding risks around modern slavery and human trafficking at the Atendco or in our supply chain they may do so either directly with their procurement contact.
DUE DILIGENCE PROCESSES AND ON-GOING MONITORING
HR
At the point of recruitment, the Atendco ensures that appropriate checks on prospective employees are completed in accordance with the law.
We monitor and ensure the organisation’s on-boarding policy is being followed on an on-going basis via an annual HR audit process.
Atendco recruitment agencies are subject to the procurement due diligence and monitoring processes below.
RISK ASSESSMENT
Atendco regularly reviews its risk profile as it relates to modern slavery and human trafficking risks, with core overarching areas of risk identified related to employment and procurement activities.
Employment:
We employ less than 10 staff in more than 3 countries worldwide. Approximately 20% of our employees work on a temporary basis outside of the UK. We offer a number of policies which support our employees with their wellbeing in addition to the policies and procedures referenced elsewhere in this statement.
Atendco is an accredited Living Wage employer. In order to maintain accredited status the Atendco has committed to pay both employees, and the staff of contractors and sub-contractors who work regularly on Atendco or client premises in the UK at or above the Living Wage rate.
Our highest areas of risk related to employment and modern slavery or human trafficking are activities conducted outside of the central Atendco operations and oversight.
TRAINING
Atendco provides its managers with guidance on the recruitment process. Training on recruitment and selection is also provided. It is compulsory for chairs of recruitment panels, and some departments make the training mandatory for all panel members, although it is also open to any interested staff. Guidance for managers on using the organisation’s internal Temporary Staffing Service and external temporary agencies is also provided.
All members of the Purchasing Department have received training on supplier review templates and guidance and have completed the HEPA Modern Slavery Act Training.
FURTHER INFORMATION
Further information may be obtained from Ed McCulloch (contact).