Modern slavery is a crime and a violation of fundamental human rights. It includes various forms of exploitation such as slavery, servitude, forced and compulsory labour, and human trafficking. All forms involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Stibo Software Group maintains a zero-tolerance approach to modern slavery and is committed to conducting business ethically, with integrity, and in full compliance with applicable laws. Stibo Software Group is dedicated to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place within its own operations or any part of its supply chains.
Stibo Software Group also promotes transparency in its business activities and expects the same high standards from its contractors, suppliers, and business partners. In line with its obligations under the UK Modern Slavery Act 2015, Stibo Software Group will integrate specific prohibitions against the use of forced, compulsory, or trafficked labour—whether involving adults or children—into its contracting processes. Suppliers are expected to cascade these standards to their own supply chains.
This policy applies to all individuals working for or on behalf of Stibo Software Group in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
This policy does not form part of any employee’s contract of employment and may be amended at any time.
Stibo Software Group holds overall responsibility for ensuring compliance with this policy, in line with its legal and ethical obligations. Stibo Software Group is also responsible for:
Management at all levels is responsible for ensuring that team members understand and comply with this policy and are provided with regular and adequate training regarding modern slavery and related risks in the supply chain.
Employees and other individuals covered by this policy are invited to comment on its content and suggest ways it may be improved. All comments, suggestions, and queries should be directed to the Chief Legal Officer.
All individuals working for or on behalf of Stibo Software Group are required to:
Suspected violations should be reported to people leader, the SLT, or through the procedures outlined in the Stibo Software Group Whistleblowing Policy.
Where appropriate – and with the welfare and safety of affected individuals as a priority – Stibo Software Group will provide guidance and support to suppliers in addressing coercive, abusive, or exploitative labour practices within their operations or supply chains.
If there is uncertainty regarding whether a particular act or working condition may constitute modern slavery, it must be raised with the Chief Legal Officer.
Stibo Software Group is committed to fostering an environment of openness and accountability. Individuals who raise genuine concerns in good faith under this policy will be supported and protected, even if their concerns are later found to be unsubstantiated.
No individual shall suffer any detrimental treatment – including dismissal, disciplinary action, threats, or any other unfavourable consequences – as a result of raising a concern related to modern slavery. Employees who believe they have been subjected to detrimental treatment should inform their people leader. If the issue is not resolved satisfactorily, it should be raised formally using Stibo Software Group’s grievance procedure.
Training on this policy forms part of the induction process for all new personnel and is supplemented by ongoing communication and training initiatives. Stibo Software Group’s zero-tolerance approach to modern slavery must be communicated to all contractors, suppliers, and business partners at the start of the business relationship and reinforced where appropriate thereafter.
Any employee found to be in breach of this policy may face disciplinary action, up to and including dismissal for gross misconduct. Stibo Software Group reserves the right to terminate relationships with individuals or organizations acting on its behalf if they are found to have violated this policy.