Modern slavery is a violation of an individual’s basic human rights. Black Dog labs recognises that as a commercial organisation it has a moral and social responsibility to take a zero-tolerance approach to modern slavery in all forms.
We are committed to preventing slavery and human trafficking in our corporate activities and to ensuring that our supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
Black Dog Labs Ltd is a management consultancy business engaged in software engineering. The company is privately owned and limited by shareholding and operates in 7 countries with the following organisational structure.
In relation to Modern Slavery we consider:
- Our primary activities to be:
- Professional consultancy on defining, building and operating software systems.
- Software engineering personnel and teams
- IT Engineering
- Our activities to be low risk as our staff and suppliers are highly skilled, very experienced and knowledgeable.
Responsibility for policies and initiatives within the organisation is as follows:
- Policies are the responsibility of our CEO and are reviewed annually.
- Risk assessments are the responsibility of our Business Unit Leads within each country.
- Investigations and due diligence for those investigations is the responsibility of our COO with the appropriate Business Unit Lead and our Global Operations team.
Awareness is raised with all employees and suppliers through our newsletters and internal blog posts. Further awareness training is provided to all individuals involved directly in the above areas of responsibility.
The following policies are appropriate for the Modern Slavery Act.
Employee Team Charter
Our Team Charter forms part of our Employee Handbook and explains the behaviours we expected of them including our expectations regarding the key tenets of the Act while at work.
We encourage all our employees to report any concerns relating to unlawful conduct, malpractice, dangers to the public or the environment, and any other matter of a serious nature. The Modern Slavery Act 2015 (the “Act”) is specifically referenced within our employee handbook.
Code of Conduct for Suppliers
We are committed to ensuring our suppliers adhere to our team Charter that is incorporated into our framework agreements. This includes demonstrating safe working conditions where necessary, treating workers with dignity and respect, and acting within the law in their use of labour. Serious violations will lead to the termination of our business relationship. We use specified, reputable employment and recruitment agencies to source labour and verify the practices of any new agency invited to act for us.
We undertake due diligence when considering taking on new suppliers, and regularly review existing suppliers. This due diligence includes:
- evaluating the modern slavery risks of each new supplier as part of our onboarding process
- conducting supplier audits where general risks are identified (see risks below)
- taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans
As a small supplier, we can keep a very close eye on risks such as these. All our subcontractors are London-based and compensated accordingly. We deem the risk of modern slavery to be low given the personal relationships involved.
- Observe. We have a very close relationship with subcontractors and regulary review practices.
This statement is reviewed annually. It has been approved by Black Dog Labs who last reviewed it on 1st January 2022.
This statement is made in the UK pursuant of section 54 of the Modern Slavery Act 2015.