Pursuant to Section 54 of the Modern Slavery Act 2015
1. Organisation Structure and Supply Chains
GEN is a UK-based internet services provider specialising in web hosting, cloud solutions, and network infrastructure, and other services. Our supply chains include:
- Hardware suppliers (servers, networking equipment)
- Data center partners
- Software vendors
- Third-party contractors for technical support
We operate primarily in the UK, with suppliers in the USA, Canada, Europe, Taiwan and China.
2. Policies
We maintain the following policies to combat modern slavery:
- Supplier Code of Conduct: Requires adherence to ethical labour practices.
- Whistleblowing Policy: Protects employees reporting concerns.
- Recruitment Policy: Ensures fair hiring practices, including right-to-work checks.
- Cybersecurity Protocols: Mitigates risks of forced labour in digital infrastructure maintenance.
3. Due Diligence
We implement:
- Risk assessments for new suppliers.
- Contractual obligations for suppliers to comply with anti-slavery laws.
- Regular audits of high-risk sectors (e.g., hardware manufacturing).
4. Risk Assessment
Key risks identified:
- Potential labour exploitation in electronics supply chains.
- Subcontractor non-compliance in overseas data centers.
Mitigation strategies include prioritizing suppliers with ISO 20400 certification and conducting unannounced audits.
5. Key Performance Indicators (KPIs)
- 100% of new suppliers screened for modern slavery risks.
- 100% of staff completed anti-slavery training.
6. Training
All employees receive annual training on:
- Identifying signs of modern slavery in operations.
- Reporting procedures for such.
Approval
This statement was approved by the partners when released and will be reviewed annually.