Modern Slavery Act
Unify Enterprise Communications Limited
Modern Slavery Act 2015 – Statement for the financial period ending 31 December 2018
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Unify Enterprise Communications Limited (“Unify”) has taken to prevent slavery and human trafficking in its supply chain and any part of its business.
This statement is made in respect of the financial period ending 31 December 2018. However, on 1 July 2018, following a business reorganisation, the staff, business, trading relationships and assets of Unify were transferred to Atos IT Services UK Limited (“Atos”) and Unify ceased trading as a separate entity. Atos is the main UK operating entity of the Atos S.E. group of companies, of which Unify is also a group company. Therefore, with effect from 1 July 2018, the Unify business began operating under Atos and adopted the steps taken to prevent slavery and human trafficking set out within the Atos Modern Slavery Statement 2019, a copy of which can be found on the Atos UK website.
Supply Chain Overview
Unify’s supply chain exists to support the sale of telecommunications hardware, software and services by Unify to its customers, as well as the operation of its day to day business operations. To achieve this, Unify procures various hardware and software components and services from suppliers located in the United Kingdom and the rest of Europe, Israel, Canada and the United States of America.
Hardware and software components
Unify, either directly or indirectly via its group companies, procures various different hardware components including IT and networking products such as servers, routers, switches, uninterruptable power supplies and telecommunications equipment including handsets and headsets.
Services
In addition, Unify, either directly or indirectly via its group companies, procures various services to support its business including:
- professional services to enable us to gather customer requirements prior to the installation of Unify systems into customer premises;
- project management services to assist with the installation, commissioning and maintenance of Unify systems at customer premises along with project advisory services;
- public network telephony, networking and data services;
- logistics services (for example, couriers and warehousing); and
- facilities services to provide corporate support to Unify.
Supply Chain Controls
Unify has taken the following steps to ensure compliance with the Modern Slavery Act throughout its business and supply chain during the period 1 January 2018 to to 31 December 2018:
- continued review of its existing supplier Code of Conduct (which every supplier is required to confirm adherence to when it is accepted as a new supplier to Unify) to ensure Unify’s supply chain is operating in compliance with the Modern Slavery Act. The Code of Conduct defines the basic requirements placed on suppliers of goods and services to Unify and sets out the responsibilities that each supplier must comply with in respect of stakeholders and the environment. In addition, due to the integration of the Unify business into Atos, Unify has increasingly adopted and implemented the Code of Conduct and supply chain requirements of Atos, which were fully adopted after 1 st July 2018;
- continued review of its existing due diligence process for prospective suppliers including the audit criteria which includes the prevention of modern slavery. This process included carrying out an audit of the supplier’s business to assess the supplier against various criteria to obtain a risk assessment score. Suppliers with a higher score were subject to further audits and more regular scrutiny by Unify during its supplier relationship to ensure that such risks do not develop to negatively affect the supply chain. As stated above, due to the integration of the Unify business into Atos, Unify increasingly adopted and implemented Atos’ supply chain processes and assessment tools which were fully adopted after 1 st July 2018; and
- the inclusion of an enhanced ethics and compliance clause in standard template agreements that are sent to new suppliers, which must be agreed before any goods or services can be procured. Such clause includes a reference to respect for human rights and includes notification requirements in the event of non-compliance as well as suspension and termination rights in the event of breach of such clause;
- Unify employees have also been invited to carry out a compulsory online Ethics and Compliance training course which was issued across the business to ensure that its supply chain operates in an ethical and compliant manner. This online training course continues to be available to across the business to all existing employees and is routinely issued to all new employees.
- A review of the existing training carried out within the business to ensure that its supply chain operates in an ethical and compliant manner including training on the prevention of modern slavery to critical departments, such as Procurement and Legal. It is anticipated that further training and information will be cascaded to reach the wider business.
Each of the steps taken above continues to be carried out on an on-going basis.
Unify acknowledges that the controls put in place to manage the risk posed from modern slavery require regular review. As such, Atos will continue to evaluate the effectiveness of the measures set out in this statement to ensure that the risk of modern slavery is mitigated.
Approved by the Board on 12th June 2019 and signed on its behalf by:
Director, Unify Enterprise Communications Limited
12th June 2019