Covenco’s approach to Modern Slavery and Human Trafficking

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 (United Kingdom) and relates to actions and activities for the financial year ending 31 December 2024.

Covenco UK Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

This policy provides a framework for addressing modern slavery and human trafficking risks within our business and supply chains. By implementing this effective policy and its associated procedures, Covenco Ltd can ensure that our business is free from exploitation and contributes to a more just and equitable global IT supply chain.

Covenco Ltd is committed to conducting its business ethically and with integrity. This includes a zero-tolerance approach to modern slavery and human trafficking.

This statement sets out the company’s policies and procedures to ensure that slavery and human trafficking are not taking place within any part of our business or in any of our supply chains.

Our Business

Covenco Ltd is a computer reseller, computer systems and parts broker and provider of managed IT services. We provide systems and hardware to businesses globally, and we deliver managed IT services to companies that are principally located within the United Kingdom.

Organisational structure

Covenco UK Limited has business operations in the United Kingdom as well as:

  • USA
  • Spain
  • Denmark

We operate in the IT sector. The nature of our supply chains is as follows: We work with all major manufacturers and supply IT equipment and services to all sectors of industry.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

  • Evaluating the slavery and human trafficking risks of new suppliers.
  • Regularly reviewing all aspects of our supply chain using mapping techniques.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance.

Our Supply Chains

We do not consider that we operate in a high-risk environment because much of our supply chain is based in the UK and in low-risk industries.

However, we recognise that our supply chains could still present potential risks of modern slavery and human trafficking, and these risks may include:

  • Forced labour:
    Including debt bondage, human trafficking for forced labour, and the exploitation of vulnerable workers.
  • Human trafficking for sexual exploitation:
    Including the exploitation of individuals for sexual purposes.
  • Child labour:
    The employment of children under the UK minimum legal age.

Related Policies

We operate several internal policies to ensure that we are conducting business in an ethical and transparent manner.  These include the following:

  • Recruitment and selection policy:
    We conduct checks on all prospective employees to verify that they are eligible to work in the UK. All employees require a Disclosure and Barring Service (DBS) check.
  • Supplier code of conduct:
    We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.
  • Whistleblowing policy:
    We operate this policy so that employees can raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal.
  • Staff code of conduct:
    We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviour. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
  • Procurement policy:
    We want to make sure that potential suppliers are committed to ensuring that slavery and human trafficking is not taking place within their own supply chains.

We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

  • Internal supplier audits.
  • External supplier audits.
  • Checking certain suppliers with external third parties for any slavery or human trafficking risks.

Our due diligence procedures aim to:

  • Identify and action potential risks in our business and supply chains.
  • Monitor potential risks in our business and supply chains.
  • Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
  • Provide protection for whistleblowers.

Our Approach

We are committed to:

  • Identifying and assessing risks: We will conduct due diligence to identify and assess potential risks of modern slavery and human trafficking within our own operations and throughout our supply chains. This may include:
    • Supplier assessments: Conducting ad-hoc risk assessments of our suppliers, considering factors such as the country of origin, industry sector, and the nature of the work.
    • Desk research: Using publicly available information and conducting online searches to identify potential risks.
    • Engagement with suppliers: Communicating our expectations to our suppliers regarding their anti-slavery and human trafficking policies and practices from time to time.
  • Actions we may take to mitigate risks:
    • Supplier audits: Conducting occasional audits of suppliers deemed to present a high risk to assess their compliance with our standards.
    • Training: Providing ad-hoc training to our employees on modern slavery and human trafficking issues.
    • Developing and implementing remediation plans: Working to develop and implement action plans to address identified risks and improve compliance where we deem necessary.
  • Monitoring and reporting we may undertake:
    • We will aim to monitor the effectiveness of our anti-slavery and human trafficking policies and procedures.
    • Publishing statements on our website setting out any new steps we have taken to address modern slavery and human trafficking risks within our business and supply chains.

Our Expectations of Suppliers

We expect all our suppliers to:

  • Comply with all applicable laws and regulations relating to modern slavery and human trafficking.
  • Maintain ethical and responsible business practices.
  • Implement effective systems to prevent and detect modern slavery and human trafficking within their own operations and supply chains.
  • Cooperate with us in our efforts to address modern slavery and human trafficking risks.

Governance

Covenco Ltd has appointed Mark Creasey, Chairman and CEO as our Compliance Officer to be responsible for overseeing the implementation of this policy.

Mark takes responsibility for:

  • Raising awareness of modern slavery and human trafficking issues within the company.
  • Encouraging monitoring and reviews of the effectiveness of our anti-slavery and human trafficking policies and procedures.
  • Reporting on progress to the Board of Directors.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

We aim to carry out a regular audit 33% of our suppliers each year.

Further Information

This statement will be reviewed and updated when necessary to reflect changes in our business and any relevant legal or regulatory developments.

Contact

For any questions or concerns regarding this policy, please contact:
Andy Youles, Director of Operations, and Mark Creasey, Chairman via this email address: [email protected]

Our compliance is based on these international obligations:

  • Modern Slavery Act 2015:
    This Act requires commercial organisations operating in the UK to publish a slavery and human trafficking statement if they have a global turnover of £36 million or more.
  • EU Directive on Corporate Sustainability Due Diligence:
    This Directive, once implemented, will require all companies operating in the EU to conduct human rights due diligence, including addressing risks of modern slavery and human trafficking.
  • US laws:
    Companies doing business in the US may be subject to multiple laws and regulations related to human rights and labour standards, such as the Foreign Corrupt Practices Act and the Trafficking Victims Protection Act.