Modern Slavery and Human Trafficking Policy   
 
Introduction Unipro is committed to continuously improving our business practices to prevent modern slavery and human trafficking. 

We have a zero-tolerance approach and strive to act ethically to ensure that modern slavery is not taking place anywhere in our company through business activities and relationships, or in our supply chains. 

This statement sets out our actions to understand all potential modern slavery risks related to our company and what practices we have in place to prevent modern slavery and human trafficking in our business. 

This statement relates to actions and activities during the financial year 1st September 2019 to 31 August 2020. 

Organisational structure 
Unipro are a Digital agency providing Web and IT solutions to e-commerce businesses. The company was established in 1997 and after 22 years has approx. 48 employees based across 3 locations. 

Countries of operation and supply 
Unipro operates in the following countries: Australia, UK & MAU 

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: 

• The Directors advised by HR and legal counsel are responsible for assessing the risk assessment process in relation to the directorate’s specific operations  

High-risk activities 

The following activities are considered to be at high risk of slavery or human trafficking: 

• Recruitment & Resourcing.   

 The company follows a strict recruitment and selection policy to ensure all relevant right to work documentation is sought from all employees.  The company works within the UK government laws and definitions to ensure all employees are paid a fair and legal wage. 
 
Relevant Policies 

Unipro operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in all its operations  

• The Directors are responsible for ensuring that all staff adhere to policy and are informed of the company’s position regarding slavery and human trafficking. The HR department is responsible for updating the aforementioned policy and for the review and monitoring of this, in conjunction with the Directors 

Whistleblowing policy 

The company encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the business. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. For more information please contact hr@theunipro.io 

Employee Code of Conduct 

The employee code makes clear to employees the actions and behaviour expected of them when representing the company. The company strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. For more information please contact hr@unipro.io

Supplier code of conduct

The company is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The company works with suppliers to ensure that they meet the standards of the code and improve their workers’ working conditions. Serious violations of the company’s supplier code of conduct will lead to the termination of the business relationship. For more information please contact hr@unipro.io 

Recruitment policy  

The company uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. For more information please contact hr@unipro.io  
Due diligence 
         
Unipro undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The company’s due diligence and reviews include  

• evaluating the modern slavery and human trafficking risks of each new supplier;

• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular; 

Performance indicators The company has reviewed its key performance indicators (KPIs).  
As a result, the business will: 

• review its existing supply chains on an annual basis whereby the organisation evaluates all existing suppliers. 

Training 

The company requires its HR department within the business to complete online training on modern slavery. 

The company’s modern slavery training covers: 

• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;

• what external help is available;

• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and 

Approval 
This statement was approved on 8th October 2019 by Shaun Froome who reviews and updates it annually.