While Crosstide Limited (“Crosstide”) is not under an obligation to publish a modern slavery statement in accordance with the Modern Slavery Act 2015, this policy sets out the steps Crosstide has taken to prevent modern slavery and human trafficking in its business and supply chains.
We know that slavery, servitude, forced labour and human trafficking (modern slavery) are issues of increasing global concern.
Hidden labour exploitation is the exploitation of job applicants and workers by third-party individuals or gangs other than the employer or labour provider, including rogue individuals working within these businesses but without the knowledge of management.
It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as forced use of accommodation. It is understood that it is often well hidden by the perpetrators from victims if they perceive themselves as such, reluctant to come forward.
Crosstide responsibility
Crosstide has a zero-tolerance approach to any kind of human rights abuses, especially within our operations and supply chain.
We are committed to respecting, protecting, and championing the human rights of all those who come into contact with our operations, including employees, contractors, supply chain workers, customers and local communities.
We accept our responsibility to support transparency and honesty; to find and resolve problems, and to work with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery.
We all have a responsibility to be alert to the risks, however small, in our business and in the wider supply chain.
As an organisation with an annual turnover of less than £36 million, the Company is not required under The Act to disclose in an annual slavery and human trafficking statement on our website the steps we have taken during the financial year to ensure our business and supply chains are slavery-free.
We are, however, encouraged to be open and transparent about our recruitment practices, policies and procedures in relation to modern slavery and to take steps that are consistent and proportionate with our sector, size and operational reach.
We would therefore ask that if you have any concerns:
- when interviewing or recruiting candidates, that they are being exploited;
- that a new team member, temp or agency worker, indicates to you that they are being exploited;
- about a supplier and their conduct in relation to modern day slavery and exploitation;
- that a colleague tells you they do not receive their salary and that it goes to someone else;
- that a colleague tells you they are living in shared and overpopulated accommodation, and they have little money and/or no food;
- please raise this with your Leader in the first instance. If you are asked by any customer/client, supplier or other external organisation for a copy of our ‘Modern Slavery Statement’, please let a senior leader know.
Our business and supply chains
Over the past few financial years, we have maintained our levels of trade to protect jobs in our supply chains and within our business. We continued to pay our consultants and suppliers on time, and we did not impose any penalties for delayed deliveries.
We currently operate in the United Kingdom, Romania and the Netherlands, and work with a network of Tech Associates (supplemented by teams employed by Crosstide) to deliver solutions for clients.
Crosstide is a Limited Liability Company (Ltd) registered in England with registered number 08477611.
Crosstide provides advice, leadership, coaching, and delivery in the technology sector to medium and large businesses.
Policies and contractual controls
Crosstide has several policies, which aim to minimise the risk of modern slavery in our business and supply chain. These include:
- Code of Conduct Policy
- Whistleblowing Policy
We firmly advocate for transparency and collaboration to eliminate risks of modern slavery, and we will take any breach of our policies or allegations seriously.
Our Customers, Employees, and Consultants have the right to raise individual concerns with our leadership team.
Due diligence processes
We believe that our greatest risk exposure to modern slavery is in our supply chains.
We have undertaken activity over previous years to minimise the risk of modern slavery by putting in place a due diligence process for new suppliers. However, the majority of the services provided by consultants and suppliers are not acquired from high-risk countries.
If we work with a supplier that may be deemed high risk, we ask that they inform us, when requested, of their Modern Slavery Act due diligence, which covers their governance, policies, training, and supply chain management processes, and details of their supply chain.
Should a supplier fail to provide the information requested, or if the information provided does not meet Crosstide’s expectations, we may press for additional information or decide not to enter into a relationship, or terminate an existing relationship, with the relevant supplier.
We aim to reassess our policies and procedures regularly and respond to any potential and actual risks in our business and supply chains.
We work with highly respected recruitment agencies and service providers in our UK operations where resources are needed.
Next steps
Crosstide has decided, among other steps, to continue in its efforts towards:
· mapping, assessing, preventing, and mitigating potential risks of modern slavery or human trafficking in relation to new and existing supply chains;
· keeping and updating its mapping of all major suppliers;
· conducting audits of the information received from suppliers to obtain a better insight into our supply chains and identify risks of any human rights abuses.
More information on how to spot the signs of exploitation can be found at www.stronger2gether.org.
Should you have concerns about an individual, you can report your concerns to the Modern Slavery Helpline on 0800 0121 700.