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Modern Slavery Statement
1: Opening statement from senior management
Svella Plc and its subsidiaries are committed to preventing acts of modern slavery and human trafficking from occurring within their business and supply chain and imposes the same high standards on their suppliers.
This statement is made at the end of the second year of trading for the Svella group of companies and demonstrates the ongoing endeavours in the group to continually enhance our commitment to combatting modern slavery and human trafficking in our business and supply chain. This statement further sets out the detail of the implementation of the key strategic initiatives that were outlined in the prior yearthat will support the group in achieving these objectives.
2: Structure of the organisation
Svella Plc acquires controlling interests in distressed and underperforming businesses, or those in exciting growth sectors, and with its dedicated and focused management approach, Svella aims to improve performance to deliver returns for all stakeholders.
This statement is made in respect of Svella Plc and its subsidiaries, which specifically includes Svella Connect Limited, a provider of digital infrastructure solutions
Svella Plc and its subsidiaries together employ over 850 people and in the most recent consolidated audited accounts, the group reported a turnover of over £92m. The business operations of the Svella group are all entirely within the UK. To find out more about the nature of our business please click www.svella.com and www.svellaconnect.com.
In order to deliver the services to its customers, Svella Connect Limited and Aberla Energy Limited has an established supply chain of subcontract labour suppliers and civils construction contractors.
The Svella group policies were reviewed by all key stakeholders across the business before implementation to ensure that they were fit for purpose to adequately seek to prevent modern slavery and human trafficking in the group as it continues with its ambitious growth strategy. The initial review was undertaken during this year and implemented across the group. The policies will be reviewed periodically to ensure that they are always fit for purpose and adhere to all regulatory requirements and best practice.
4: Due diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted a number of due diligence procedures which include thorough supplier onboarding procedures comprising, where appropriate and applicable, site visits and accreditation/ certification verification, periodic and ad hoc supplier visits and audits, collation and continuous updating of supplier registers and internal and external training.
Our procedures are designed to:
• establish and assess areas of potential risk in our business and supply chains
• monitor potential risk areas in our business and supply chains
• reduce the risk of slavery and human trafficking occurring in our business and supply chains
• provide adequate protection for whistleblowers
During this year we have invested in systems, process and people in our operations specifically focused on procurement and onboarding of suppliers and our supply chain.
5: Risk and compliance
The Svella group regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain through its regular reviews and analysis of its supply chain both at an operational and board level.
We do not consider that we operate in high risk sectors or locations because all of our operations are delivered solely in the UK. Our labour supply chain is also all UK based and relies on skilled labour from a core group of suppliers that we look to establish long term trusted partner relationships with.
Where we have identified a potential risk, for example the requirement to quickly resource new projects, we seek to mitigate this as much as possible by preferring to directly employ the labour resource or working with our partners to agree a programme of works that allows appropriate assessment and engagement of suppliers and labour resource.
We ensure all our suppliers adhere to our policies and standards. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find any gross failure to comply with our policies, including those relating to modern slavery or human trafficking in our supply chain we will immediately seek to terminate our relationship with the relevant supplier.
6: Effectiveness and KPI
The Svella group is committing to investing in best in class systems to improve the efficiency and productivity of its business. The systems will enhance supplier onboarding and audit processes, collate required records and provide real time data across the business regarding the delivery of its operations and the suppliers and labour involved in those processes. This will enable the business to have control and immediate knowledge of any points of concern to enable it to be proactive in the prevention of modern slavery and human trafficking within its business and supply chain.
With these systems now in place the business is better placed to report on its data and analyse any trends from which to establish any key performance indicators against which it can measures its success in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains, make reports to the board and promptly take action where this data identifies any exceptions or concerns in compliance.
We are investing in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees and stakeholders are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. This training is a combination of remote e-learning modules curated by our specialist training provider, and in-person training for new starters and existing employees at induction sessions and refresher training. During this year the senior leadership have developed and rolled out a comprehensive new starter induction programme and we have invested in a learning management system providing bespoke training curriculums for each job role.
8: Further actions and sign-off
Over the following years the Svella group is committed to maintaining its strict zero tolerance approach to modern slavery and human trafficking in its business and supply chain as it continuous with its ambitious growth strategy.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement for the financial year commencing 1 May 2022 and ending on 30 April 2023 for Svella Plc, on its own behalf and that of its subsidiaries, including Svella Connect Limited.
This statement was approved by the Board of Directors of Svella Plc.
Date: 31 October 2023