Modern Slavery & Human Trafficking Statement

This statement sets out Mindera's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year ending December 2023.

Mindera is committed to improving its practices to combat and ensure that its supply chains are free from slavery and human trafficking.

Our business

Mindera is a provider of services in the technology sector. We are a part of the Mindera group of companies (Group) which operates from locations around the world, with our ultimate parent company having its head office in the UK.

Our supply chains

We are a technology business providing services to businesses worldwide. Our workforce is highly skilled, due to the technical nature of our offering, and we have a relatively small supply chain. Mindera operates with strategic and critical suppliers. Our supply chain is largely characterised by the purchase of IT and technology, software licences, telecoms, communications, marketing, and professional services.

We have undertaken a proportionate risk assessment in line with the requirements of the Modern Slavery Act 2015. Due to the nature of our business and the skill levels required from our people and business partners we believe that our business and supply chains are at a ‘low risk’ of potential for slavery or trafficking.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains. Training and information on this policy is provided to all our people to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business.

Our specific policies on key social and ethical issues, for example, our Human Rights and Labour and our Anti-Bribery and Corruption policies, outline the standards and behaviours that we expect from all our people, wherever they are in the world, whatever local practices are and wherever they conduct business on behalf of the organisation.

Mindera encourages all its people, customers and other business partners to report any concerns related to the direct activities, or the supply chains of the organisation. The organisation's whistleblowing procedure is designed to make it easy for everyone to make disclosures, without fear of retaliation.

Due diligence processes for slavery and human trafficking

Internally, we have a number of processes in place to verify the identity of our workforce to make sure we know exactly who is working for us. We carry out appropriate checks on all our people which may include reference, qualification and licence checks, depending on their role.

As part of our initiative to identify and mitigate risk our due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier; and
• protecting whistleblowers.
  

Our effectiveness in combating slavery and human trafficking

Following a review of the effectiveness of the steps we have taken in 2023 to ensure that there is no slavery or human trafficking in our supply chains, Mindera commits to:

• continuously assessing and reviewing exposure to slavery and trafficking risks across the Group’s supply chain and taking the necessary steps to mitigate any risks identified.
• annually publishing progress and developments within the Group’s practices in relation to the objectives of the Modern Slavery Act 1995.
  

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending December 2023. Approved and signed on behalf of the Board of Mindera, Paul Evans CEO, 27 February 2024.