Anti-Slavery Policy
BroadShield has a zero-tolerance approach to slavery and is committed to preventing acts of slavery and human trafficking from occurring within both its business and supply chain, and imposes those same high standards on its contractors, suppliers and other business partners.
Modern Slavery Statement
Organisation
This statement applies to BroadShield Ltd (referred to in this statement as ‘the Organisation’). The information included in the statement refers to the financial year ending 31st March 2025.
Organisational Structure
BroadShield operates through its Head Office located in Stevenage, Hertfordshire, United Kingdom.
The Organisation comprises of a number of departments, each reporting in to into a member of the Senior Management Team (SMT). The SMT reports directly to the CEO and business owner. Employees work from the Organisation’s Head Office with some contractual staff operating remotely.
BroadShield delivers workforce development solutions across the Health and Social Care sector. Solutions such as eLearning, competency, staff development, performance management, and apprenticeship qualifications are provided through a wholly owned technology platform, Myrus. Demand for our products is consistently high throughout the year, with little seasonal fluctuation.
The labour supplied to BroadShield in pursuance of its operation is carried out in the UK.
Definitions
BroadShield considers that modern slavery encompasses:
Human trafficking;
Forced work, through mental or physical threat;
Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
Being dehumanised, treated as a commodity, or being bought or sold as property;
Being physically constrained or to have restriction placed on freedom of movement.
Commitment
BroadShield acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. BroadShield understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
BroadShield does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to BroadShield in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. BroadShield strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
Supply Chains
To In order to fulfil its activities, BroadShield’s main supply chains include those related to the supply of goods and services from various suppliers in the United Kingdom. We understand that BroadShield first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.
Potential Exposure
BroadShield considers its exposure to the risk of slavery and human trafficking to exist in line with local risk factors in each country. These risks are considered to be low.
In general, BroadShield considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
BroadShield identifies the following as the principal areas of potential risk:
Supply chains for goods and services, particularly IT equipment, outsourced maintenance, and delivery services.
Recruitment agencies for temporary staff.
Steps
BroadShield carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
BroadShield has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, BroadShield will adopt due diligence processes that are proportionate to any risk areas identified (dependent on the severity of the risk and other relevant factors). These processes will be subject to on-going assessment and review.
Any supplier or potential supplier wishing to supply or to partner with BroadShield must provide evidence that they operate a high level of corporate social responsibility and comply with the Modern Slavery Act 2015. BroadShield has a policy in place to protect whistle-blowers.
Key Performance Indicators
BroadShield has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place internally or its supply chains.
Where BroadShield has identified risks of modern slavery occurring in any part of its services, it will aim to introduce performance indicators (KPIs) to measure progress against reducing such risks. The Company will consider setting and reviewing KPIs in the following contexts:
Use of grievance and whistleblowing procedures by staff to raise concerns about instances of modern slavery
Assessment of third-party suppliers of relevant goods and services and their supply chains.
This statement will be made available to all staff members, stakeholders, and the general public. We will also seek to raise awareness of the risks of modern slavery amongst staff by other measures, including discussion of this statement during the induction process for new employees.
Policies
BroadShield has the following policies which further define its stance on modern slavery:
Grievance and Whistleblowing policies - these policies allow employees, learners, and others to raise concerns, which would include circumstances giving rise to a risk of modern slavery, without fear of retaliation.
Employee Code of Conduct - this code sets out the actions and behaviour expected of them whilst employed by BroadShield. The Company strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.
Anti-bribery and corruption policy – BroadShield is committed to the highest standards of ethical conduct and integrity in its business activities. BroadShield will not tolerate any form of bribery or corruption by its employees or any person or body acting on its behalf.
Procurement policy - this policy reflects BroadShield’s commitment to acting ethically and with integrity in its business relationships, as well as implementing and enforcing effective and proportionate safeguards and controls.
Training
Having assessed the training needs for all staff operating in the company, BroadShield will look at devising and implementing training and awareness raising methods attuned to relevant staffing groups. Training courses may be devised in cooperation with external, specialist training providers.
Slavery Compliance Officer
BroadShield has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to BroadShield’s obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.
Updated April 2024 (Policy CSQP043 issue 3)