Modern slavery statement for 1 February 2023 to 31 January 2024
This statement sets out the steps that Mitratech Holdings, Inc. (“Mitratech”) has taken and is continuing to take to ensure that modern slavery and human trafficking is not taking place within our business or supply chain. This statement relates to the period 1 February 2023 to 31 January 2024.
Mitratech has a zero tolerance approach to any form of modern slavery, including servitude, human trafficking and forced labour. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against modern slavery within our business and supply chain.
This statement covers the activities of Mitratech and its subsidiary companies (as defined under the Companies Act 2006):
- Mitratech is committed to solving the complex needs of legal and compliance professionals.
- Mitratech has offices in the United States, United Kingdom, India and Australia, with the majority of our business conducted within the United States. Our contractors and suppliers are primarily based within the United States and United Kingdom.
- Products, services and software development are generally provided in-house by Mitratech, rather than by third parties.
Mitratech maintains on-going due-diligence of its material suppliers to assess whether any particular risks of slavery or human trafficking within its supply chains or any part of our business. We have zero tolerance to slavery and human trafficking. We evaluate our relationships with professional or business services suppliers, such as those who provide hosting support services to identify any potential risks. In part, we manage this risk through the use of suppliers whom are considered to be reputable, and we have specifically requested all material regular suppliers to confirm that their own business activities and supply chain do not involve slavery or human trafficking.
We have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
We also operate a number of internal policies to ensure we conduct business in an ethical and transparent manner. We continuously review and update all our policies. These include:
- Corporate Social Responsibility Policy. This policy set out our commitment to promoting equal human rights for all, as well as monitoring the social, economic, and environmental impacts of our business.
- Anti-Bribery and Corruption Policy. This policy underpins our commitment to maintaining high standards of ethics, morality and legality in all areas where our business is carried out.
- Recruitment policy. We conduct eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees, without fear of reprisals, can raise concerns about inappropriate behaviour and practices across our business or supply chain.
- Employee handbook. This handbook explains our code of conduct; the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Our Performance Indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain (i) by monitoring how we and our suppliers perform against our standards and policies and (ii) if no reports are received from employees, suppliers, the public or law enforcement agencies to indicate that modern slavery practices have been identified. In the prior year, we have not been made aware of through our due diligence and have received no reports from employees, suppliers, the public or law enforcement agencies of alleged modern slavery practices within our business or supply chain.
Steps Mitratech will take in 2023
(A) Continued management responsibility and general awareness
- Report progress to the executive management team and the Board.
- Raise awareness of this published statement to suppliers who are regularly engaged with.
- Determine if a modern slavery questionnaire to be completed by our key suppliers should be implemented within our supplier due diligence.
- Develop framework to ensure consistent standards and effectiveness across our business.
(B) Risk assessment
- Re-evaluating the risk of non-compliance as part of our cyclical compliance risk register assessment:
- Act promptly where a compliance breach has been identified or flagged.
- Re-evaluate appropriate processes for remediation of risks identified within our business or within our supply chain.
- Continue to feed lessons learned back into our compliance risk management process.
(C) Risk mitigation
- Improve upon our training. Provide additional training opportunities to our employees on identifying and addressing modern slavery awareness. Ensure our suppliers and business partners provide training to their employees and suppliers and providers.
- Taking steps to ensure our contracts require our suppliers adhere to our relevant policies or adhere to equivalent policies.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Mitratech’s statement for the period 1 February 2023 to 31 January 2024.
This statement has been approved by Mitratech Holdings, Inc.’s board of directors, who will review and update it annually..
9 March 2023