tier1 – Moderns Slavery Act and Company Policy

1. 
   

   Structure, business and supply chain

Tier 1 Asset Management Ltd. is one of the UK’s leading secure ICT disposal specialists.

We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen. In that spirit, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement on behalf of Tier 1 Asset management Ltd., as relevant. Our efforts against slavery and human trafficking complement our broader CSR Policy and our adoption of the Ethical Trading Initiative.

Tier 1  is headquartered in Whitefield, Manchester and provides asset management services predominantly in the UK and occasionally in Europe. We have 54 employees within our organisation. Where possible, we engage suppliers who have relationships with existing suppliers so that we can contain our supplier network and improve consistency in ethical practices throughout the supply chain

Building on our existing CSR Policy and our commitment to our Ethical Trading Policy, we have embraced the requirement to publish an annual slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year. This past financial year ending 31 March 2019, we took the following key steps to ensure slavery and human trafficking did not occur within our organisation or supply chain.

2. 
   

   Slavery and human trafficking policies

Notably, we published our first Modern Slavery Policy to ensure compliance with our customers’ requirements. It sets out clear objectives for 1, 3 and 5 year slavery and human trafficking plans around the following themes:

• Relationships: Strengthening our supplier engagement process
• Feedback: Establishing grievance mechanisms and channels for individual worker feedback
• Knowledge: Improving our knowledge base by collecting relevant data and improving product traceability
• Third party engagement: Building strategic alliances with independent social auditors, unions and NGOs
• Measurable change: Developing verifiable KPIs to measure progress
• Supplier collaboration: Encouraging suppliers to collaborate to address slavery and human trafficking issues
• Incentivisation: Developing mechanisms to incentivise employees and suppliers to address slavery and human trafficking and improve labour standards
• Accountability: Establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking

3. Due diligence procedures

We understand that our biggest exposure to Modern Slavery is in our product supply chains, where we have undertaken activity over the last decade to minimise the risk of Modern Slavery. Within these areas, new suppliers and factories/sites are subject to due diligence checks in the form of ethical/compliance audits. Such audits are also regularly conducted for existing suppliers and factories/sites. These audits assess compliance with the Global Sourcing Principles and are, amongst other things, intended to identify any Modern Slavery practices. If issues are identified, appropriate investigative and remedial actions will be taken.

4. 
   

   Identifying, assessing and managing risk

We set out to identify the extent of any slavery and human trafficking in our supply chains by:

• Engaging third party auditors to conduct audits at our site
• Interviewing employees to discuss their conditions and their rights
• Collaborating with 2 of our suppliers to develop an improvement plan to address new and previously identified slavery and human trafficking issues

We discovered slavery and human trafficking to be absent in the parts of our supply chain involved in our asset management service. Maintaining this absence of slavery and human trafficking on our suppliers’ industries will be our focus point for the next financial year.

5. 
   

   Key performance indicators

In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:

• Staff training levels
• Number of slavery incidents reported in the supply chain

6. 
   

   Training available to staff

A key part of our slavery and human trafficking strategy is to promote cultural change through training. This next financial year we will:

• Deliver training modules on modern slavery to all staff
• Start the development of a dedicated training and resources which individual workers in the supply chain will be able to access to learn about modern slavery and human trafficking, understand their rights and anonymously report any slavery and human trafficking issues in their workplace.

Jonathan Rose
Managing Director