Slavery and Human Trafficking Statement for the year ending 31 March 2021 

This statement sets out Nuvias Group’s1 actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2020 to 31 March 2021. 

As part of the IT distribution industry, Nuvias recognises that it has a responsibility to take a robust approach to slavery and human trafficking and continues to take its responsibility very seriously during the coronavirus pandemic. 

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking. 

Organisational structure and supply chains

This statement covers the activities of Nuvias:

Nuvias is a solutions-led flexible and adaptable IT Security pan-EMEA distributor that provides services and solutions to enable the channel and vendor community to deliver exceptional business value to customers, enabling a new standard of channel success. 

Nuvias’ central supply chain is to consist of one dedicated purchasing entity across the Group. 

The organisation currently operates in EMEA. Nuvias has multiple offices across EMEA which allows the channel to expand and grow across all countries. 

Our Group structure is currently split across several regional Hubs that provide support to countries in those regions: 

  • North (includes UK & Ireland, Nordics, Benelux) South (includes France, Italy, Spain, Med)
  • Central (includes Germany, Poland, Switzerland, Austria, Hungary, Romania) MEA (includes Dubai, Saudi Arabia). 

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking: 

Responsibility 

Responsibility for our anti-slavery initiatives is as follows:

Policies: The Nuvias Group Board of Directors, led by the Operations Director, is responsible for putting in place and reviewing policies and the process by which they were developed.

Risk assessments: The Nuvias Group Board of Directors, led by the Operations Director, is responsible for the process and broad organisational responsibility for human rights and modern slavery risk analysis.

Investigations/due diligence: The Nuvias Group Board of Directors, led by the Operations Director, is responsible for any investigations and due diligence in relation to known or suspected instances of slavery and human trafficking. Their precise roles will be determined by the specific incident and or occurrence at any given time.

Training: The Nuvias Group will establish a programme of training in the coming financial year for all relevant staff to enable them to better understand and respond to any identified slavery and human trafficking risks. 

Relevant policies 

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy: We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential helpline. 01789 332716

Employee code of conduct: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chains.

Supplier/Procurement code of conduct: We are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers are required to acknowledge our “vendors code of conduct “and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the standards of the code. 

Due diligence 

We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers. Our due diligence and reviews include : 

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • Evaluating the modern slavery and human trafficking risks of each new supplier
  • Reviewing periodically all aspects of the supply chain based on the supply chain mapping;
  • Conducting supplier audits or assessments through the organisation’s own staff which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • Using https://www.modernslaveryregistry.org, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular.

Performance indicators 

The Nuvias Group Board of Directors, led by the Operations Director, is responsible for ensuring adequate procedures are in place and are adhered to. 

Nuvias Group is in the process of developing a system for reviewing its supply chains. In addition, we propose to launch a programme of training for all relevant staff over the course of the year. Both activities will have been completed by the end of the financial year. 

Training 

The Nuvias Group will establish a programme of training in the coming financial year for all relevant staff to enable them to better understand and respond to any identified slavery and human trafficking risks. 

This will require staff working across the Group to complete training on modern slavery as a module within our wider human rights and ethics training programme. 

Board/Member approval 

This statement has been approved on 1st July 2021 by our board of directors, who review and update it annually. 

Julian Hodge
Chief Finance Officer 
1st July 2021

1 Nuvias Group, which includes Nuvias (UK & Ireland) Limited, Nuvias Global Services Limited, Siphon Networks Limited, Nuvias B.V. (The Netherlands)