Modern slavery and human trafficking statement for 2019 - 2020

This Statement details the steps we have taken during our last financial year towards ensuring that slavery and human trafficking are not taking place either in our organisation or in our supply chain. Stormfront has a long-standing commitment to operating ethically and the prevention of slavery and human trafficking is an important part of that commitment.

We believe that our anti-slavery and human trafficking strategy described in this Statement is proportionate to the risks we face in our business and supply chain and any risks are mitigated by existing and new policies, procedures, training and diligent procurement processes.

Our organisation
Stormfront employs over 300 employees in the UK. We are the UK's largest Apple Premium Reseller and market leader in the provision of Home Technology Employee Benefits to UK Blue Chip companies.

Our business
We categorise our business into two areas to manage the risks:

  • Our own staff
  • Our supply chain

Own staff
We aim to be an ethical employer and our HR policies are designed to prevent any occurrence of modern slavery or human trafficking in our employment practices.

We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will. We support this by recruitment training to our managers.

Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

To further improve awareness, as part of our training programme we will include training to relevant managers and staff on slavery and human trafficking. We will update the Staff Handbook with a reinforced commitment to anti-slavery alongside the policy commitment in the Environmental & Corporate Social Responsibility Policy.

Our supply chain
We monitor the effectiveness of our key suppliers in their efforts to prevent slavery and human trafficking in their businesses. We do this by:

  • Assessing the risk areas within our supply chain on a company by company basis
  • For significant suppliers or suppliers with a high risk, reviewing the controls that our suppliers have in place to prevent slavery and people trafficking
  • Where we are not satisfied that a supplier has sufficient controls, we work with that suppliers to improve the situation. If we are not confident that this will work, we will change supplier.

We also are in the process of embedding a specific commitment to preventing slavery and human trafficking into our Environmental & Corporate Social Responsibility Policy, which will be available on our website together with this Statement. This Policy commitment will be underpinned by the following:

  • Zero tolerance approach, reinforced by the Staff Handbook and staff training
  • A procurement policy incorporating pre-contractual supplier due diligence
  • Regular risk assessments
  • Whistleblowing procedures

We are also in the process of launching a Supplier Code of Conduct ("Code") which communicates our ethical approach to doing business to our suppliers, including slavery and human trafficking. The Code requires our suppliers to have in place effective policies and procedures which reflect similar ethical commitments and to cascade this down their own supply chain. Any violations must be reported to Stormfront and failure to adhere to the Code may result in a termination of supply, reduced volume of business or non-inclusion in future tender opportunities.

Our due diligence processes
Our supply-chain due diligence processes are proportionate to the level of assessed risk and the level of control or influence we have in each relationship.

New suppliers:
Where we take on a new supplier we require them to respond to our pre-contractual due diligence questionnaire which will specifically address slavery and human trafficking. All new suppliers will also be required to agree to our Code of Conduct.

Existing suppliers:
Our Code will be launched initially across the Core suppliers which represent the vast majority of our supply-chain. Subsequently we will look to launch the Code, where possible, across Services supplier groups. We will also aim to conduct monitoring and audit of target suppliers to ensure compliance with the Code.

Monitoring and managing risk
We assess risk in our supply chain through consultations with relevant internal stakeholders. Risk factors include: the location of the supplier, the nature / type of the goods or services provided, the level of control we have over the supplier, the levels of corporate governance demonstrated by the supplier and the supplier's own supply chain.

Following this consultation process we have assessed our exposure to the risk of slavery and human trafficking as low for the following reasons:

  • We are entirely UK based.
  • Almost all of our direct suppliers have strong levels of corporate governance and are based in countries where slavery and human trafficking are low risk.
  • We perceive our greatest exposure to risk (albeit still limited) is further down our supply chains - broadly where workers receive low pay for low skill work, or where raw materials and manufacturing originate in high risk countries. Activities further down our supply chain are out of our direct control. As such we have focussed our efforts on our direct suppliers, most of which are UK-based and therefore obliged to comply with the Modern Slavery Act as well.

We will continually review the risks throughout the course of the year and report on these in our subsequent Statement, along with any further actions that we believe are necessary to prevent modern slavery and people trafficking in our business.