SCISYS PLC Anti-Slavery Statement
SCISYS PLC Anti-Slavery Statement
1. Modern Slavery - context
The Modern Slavery Act 2015 („the Act“) requires certain businesses to provide disclosures about the way they address issues, if any, in their supply chains concerning slavery and human trafficking.
SCISYS PLC and its subsidiaries recognise and firmly believe that modern slavery, human trafficking and forced labour is an abhorrent abuse of human rights which pervades communities across the globe.
Therefore these disclosures are aimed to provide SCISYS shareholders and the public better information on the way SCISYS complies with the Act.
SCISYS is committed to implementing and maintaining policies and procedures to avoid complicity in human rights violations that could occur as a result of its business operations either directly or through using its supply chain. There are many forms of coerced labour and this statement seeks to encompass all types that could occur as a result of SCISYS operating its business.
2. Group structure and Corporate Governance
SCISYS PLC is quoted on AIM. In the UK, SCISYS PLC holds 100% of the shareholding in SCISYS UK Limited and is based in Chippenham, Wiltshire, UK. Xibis Ltd is a smaller, wholly owned, subsidiary of SCISYS PLC and is based in Leicester.
In Germany, SCISYS Deutschland GmbH is based in Bochum, Germany, and is owned by SCISYS PLC (11%) and SCISYS Deutschland Holding GmbH (89%). ANNOVA Systems GmbH is also wholly owned by SCISYS Deutschland Holding GmbH. In turn, SCISYS Deutschland Holding GmbH is wholly owned by SCISYS PLC.
As an AIM quoted company SCISYS is not subject to the UK Corporate Governance Code, but applies it where appropriate for a company of its size. The SCISYS board ensures good corporate governance is undertaken. It has robust and accessible governance structures in place, implemented through detailed PLC policies and procedures, together with a risk register, which is reviewed at least annually by the executive Directors and the Company Secretary. Legal updates are also brought to the PLC board’s attention by SCISYS’ General Counsel. The PLC board is aware of its obligations under the Modern Slavery Act 2015 (“the Act”) and is committed to operating its business on an ethical basis and sets the tone for an ethical culture within the SCISYS group.
3. Slavery and Human Trafficking Statement
This statement is written for the SCISYS group (“SCISYS”).
SCISYS has a zero tolerance policy and requires its supply chains to be transparent and accountable in this respect. SCISYS will not support a supply chain where SCISYS is aware of or has reasonable grounds to believe that modern slavery is taking place. SCISYS will terminate supply contracts in these circumstances, wherever possible. SCISYS is carrying out a number of steps to develop an appropriate and effective response to the requirements of the Act as part of its commitment to comply effectively.
SCISYS is confident that slavery and human trafficking it not taking place by SCISYS towards its own staff. SCISYS predominantly employs staff in the UK (SCISYS UK Limited) and in Germany (SCISYS DE). Occasionally staff work in other European countries on a short term basis. All staff are employed under employment conditions and are required to sign an employment contract.
SCISYS provides bespoke software solutions and software products for a range of clients, including blue chip corporations and the public sector. It is primarily a “people business” and depends upon its staff to write and manage complex IT software solution projects. SCISYS meets and exceeds the national minimum wage and follows the living wage standard where applicable. Since 1 January 2015 there is a general minimum wage in Germany. Compliance with the Minimum Wage Act (Mindestlohngesetz) is ensured by imposing a criminal responsibility of the employer as well as a liability for the employer’s commercial customers.
Additionally SCISYS purchases hardware and IT equipment and licences through a purchasing procedure either operated by or devolved to its trading divisions or via a central department. This equipment and software is purchased predominantly within Europe from large companies, which will have their own modern slavery policies in place. SCISYS believes that the risk of modern slavery occurring is considerably higher for purchases outside Europe, and this will be taken into account when choosing suppliers.
SCISYS annual spend on such purchases is less than 10% of its total group turnover.
The supply chain comprises predominantly blue chip companies who SCISYS regularly audit. Compliance with the Act now forms part of that audit process.
SCISYS verification process involves at least a two-yearly assessment of its major suppliers by way of a self-assessment questionnaire. In addition SCISYS reserves the right to audit individual suppliers on an “as needed” basis to verify compliance.
SCISYS though is also seeking to raise awareness about the possibility of indirectly supporting slavery through its third party supply chain. Staff are being made aware of this through staff induction and training. To that end, staff are encouraged to seek assurances from suppliers that they are taking steps from within their own supply chain to identify and tackle possible areas of modern slavery. Awareness information is regularly updated to staff via the group intranet as part of its supply chain management. Staff are able to report any concerns to the Company Secretary who will take appropriate and prompt action.
Where appropriate SCISYS will seek contractual terms requiring its suppliers to have in place and provide when requested a copy of their own modern slavery policies. Its standard terms and conditions also reflect the requirements of the Act.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes SCISYS' slavery and human trafficking statement, appearing on the SCISYS’ website and also in the PLC policies section of the SCISYS intranet, which is available to all group staff. This statement will be reviewed at least annually.