NEWS FRAMEWORKS PARTNERS CUSTOMERS ABOUT CONTACT SEARCH Modern Slavery Statement 2021 Bramble Effect Group Anti-Slavery and Human Trafficking Statement for the year ending 31st July 2021 Introduction from the Board The Bramble Effect Group fully supports the government’s objectives to eradicate modern 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 companies: have not been convicted of any slavery or human tracking offenses anywhere in the world. are not currently under investigation, inquiry or enforcement proceedings in relation to any allegation of slavery or human tracking offences anywhere around the world (as far as we know). Organisation structure and supply chains Bramble is a small owner managed group of companies: Bramble Hub Limited, Bramble Accelerator Limited and Bramble People Limited; and their holding company: Bramble Effect Limited. Bramble Hub specialises in UK public sector framework contracts for IT and related professional services consultancy. It does this by winning a place on relevant UK public sector frameworks and then involving our network of over 200 subcontractors (“Partners”), almost all SMEs based in the UK (with a few global companies trading in the UK, and a few others based in Europe or USA), to secure and deliver contracts. Bramble Accelerator provides consultancy to Bramble Hub partners. However, this year, it has not been active. Bramble People provides recruitment services to Bramble Hub partners (and a few other UK-based IT companies on occasion). During the past year, it has only been engaging single numbers of UK-based IT contractors to one customer – a well established and well-known partner, who sells them on to a single project inside the Home Office and some police forces. Given the customer and nature of this work, it is extremely low risk. The rest of this statement focuses on Bramble Hub, although some items apply to the whole group. Our policies in relation to slavery and human trafficking Our anti-slavery policy is managed and maintained as part of our Quality and Environmental Management System (QEMS), which is subject to internal audit and external ISO audit and certification. The policy (which applies to the whole group) reflects our commitment to acting ethically and with integrity in all our business relationships, helping to ensure that slavery and human trafficking is not taking place anywhere in our business. It confirms that, as a matter of policy, we: 1. Do not use forced, bonded or involuntary prison labour. 2. Do not allow our subcontractors to use forced, bonded or involuntary prison labour (which we are contractually enforcing where we can for new contracts). 3. Do not require any of our staff or our subcontractors’ staff to lodge deposits or identify papers with their employer, and that staff are free to leave their employer after reasonable notice 4. Have working due diligence procedures to manage and reduce the risk of slavery or human trafficking in our supply chain performing obligations. 5. Do not use, and do not allow our employees or subcontractors to use, physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of our employees or subcontractors. Our employment contracts and associated employment policies and procedures ensure our employees are not allowed to do this. 6. Do not use or allow child or slave labour to be used by our subcontractors. 7. Would report the discovery or suspicion of any slavery or trafficking by us or any of our subcontractors to relevant customers and the Modern Slavery Helpline, if the situation arose. All employees and partners understand that they have a statutory obligation to report knowledge or suspicion of slavery or human trafficking and may do so without fear of discrimination or reprisal. Related policies and procedures Over the coming months, we will be further reviewing our other relevant policies and procedures (for the whole group) to include references to modern slavery and human trafficking where relevant. These may include: Equal Opportunities and Diversity Policy Ethical Purchasing policy Partner Risk Management Procedures The overall responsibility for the policies lies with the Managing Director. Due diligence processes We have taken the following steps to achieve and confirm compliance with the Modern Slavery Act 2015: We have: 1. Reviewed the Modern Slavery Act 2015 and undertaken the suggested Risk Assessment for ourselves (our whole group) and our supply chains. This was issued on 21st July 2021. The conclusions have been included in this Statement and will be reviewed annually. 2. Reviewed the policies, procedures and templates within our ISO 9001 quality management system (QMS) and employee policy/procedure handbook (for the whole group), updated them as necessary (only minor updates were required). The changes were confirmed at a meeting on 21st July 2021, communicated to all staff on 26th July, and added to our internal audit schedule to ensure that they form part of the annual quality management review. 3. Made reasonable enquires (across the group) to ensure our officers (directors), employees and subcontractors have not been convicted of slavery or human trafficking offenses anywhere around the world. This was confirmed at a meeting on 21st July 2021 4. Reviewed our subcontracts (for the group), ensuring appropriate anti-slavery, -tracking and -trafficking clauses are included and/or flowed down where possible. All our subcontracts flow down responsibilities and commitments from government framework agreements. The majority of those agreements recently issued include Modern Slavery clauses; older agreements will generally do so as they are renewed; this is up to the government (civil servants and public sector officers) to make happen. We will continue to review this. 5. Built and run an online form using Zoho Forms, using which our subcontractor delivery partners confirm their ongoing commitment to compliance with the Modern Slavery Act 2015. Partners are required to sign the form as part of the partnership registration process and before they can participate on Bramble Hub contracts, to confirm that they conform to the following principles: That the Company does not use, nor allow any of its subcontractors to use, forced, bonded, or involuntary prison labour. That the Company or any of its employees, directors, officers and any personnel involved in the delivery of the Services under a Contract has not been convicted of any slavery or human trafficking offences anywhere around the world. That the Company does not use, nor allow any of its employees, officers or subcontractors to use physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation of its employees or subcontractors. That the Company does not use, nor allow any of its subcontractors to use, child or slave labour. This form, signed by an appropriate authority from within the subcontractor gives us a formal record to evidence the ongoing compliance of our supply chain. Partners are required to recommit to these principles annually. Risk assessment The assessment of the potential for slavery or human trafficking in our organisation and our supply chains is judged to be VERY LOW, based on our small, owner-managed company, the work we do and the suppliers we work with. Training on modern slavery and trafficking To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have included our Modern Slavery Policy and Statement in the induction training for new employees. All staff participated in an online Teams briefing on 26th July 2021 and this will be integrated into our annual refreshment training programme for all employees, audited and evidenced under ISO 9001. Key performance indicators to measure effectiveness of steps being taken We have incorporated the following Key Performance Indicators (KPIs) into our regular internal audit checks: All partners’ online commitments to Modern Slavery principles are up-to-date (CRM checked) No reports received of slavery or human trafficking (confirmed by MD) All staff aware of the risks of modern slavery and human trafficking (confirmed 100% participation in July 2021 briefing). This voluntary slavery and human trafficking statement is made in connection with section 54(1) of the Modern Slavery Act 2015. It was approved by the board on 5th August 2021. Signed by: Richard Archer, Managing Director Date: 6th August 2021 VIDEOS ABOUT BRAMBLE HUB PARTNER LISTINGS TEAM 020 7735 0030 contact@bramblehub.co.uk Bramble Hub Ltd 9e Albert Embankment London SE1 7SP Registered Company Number 4136381 Terms and Conditions | Privacy | Cookie Policy | Modern Slavery Statement | Carbon Reduction Plan Squarespace development by Build14me By using this website, you agree to our use of cookies. We use cookies to provide you with a great experience and to help our website run effectively. Please visit our Cookie Policy for further information Accept