Modern Slavery Policy

1. Introduction

Enzai is a UK-registered Private limited Company which provides Software-as-a-Service to businesses across the UK, Europe and North America. Enzai is committed to combating modern slavery and human trafficking.

What is Modern Slavery?

Modern slavery is an umbrella term that covers the offences of human trafficking and slavery, servitude and forced or compulsory labour, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. It is a highly complex and hidden crime that is a violation of fundamental human rights. The UK Government has estimated there are 13,000 victims of modern slavery in the UK and the number is increasing.

The Modern Slavery Act 2015

While the risks of modern slavery in Enzai’s direct activities are likely to be low, there are potential risks of modern slavery through goods and services procured that can be linked to supply chains around the world.

2. Scope

This policy applies to all people working for Enzai in any capacity and location, including employees, agency workers, contractors, suppliers and partnership organisations. All covered persons have responsibilities under this policy and if they suspect someone is being exploited or ill-treated then must discuss these concerns with the appropriate person. Suppliers will be required to demonstrate that all reasonable steps are taken to eradicate modern slavery in their supply chains. The safety of all staff is accorded utmost priority and is the shared responsibility of all staff at Enzai. 

This policy has been informed, and is compliant with relevant equality and diversity legislation. It is not anticipated that the policy will have any negative impact on any protected groups.

3. Purpose and key focus areas

Enzai aims to use all reasonable endeavours to ensure that no modern slavery or human trafficking is taking place in our institution or in any part of our supply chains and that whistleblowers are protected.

Focus areas included adequately training all employees to spot potential modern slavery, ensuring that the supply chain remains free of such practices, and protecting potential whistleblowers.

4. Modern Slavery Policy

Under this policy Enzai endeavours:

4.1. Governance structure

To empower a designated individual to identify and assess potential risk areas and use processes to remove the potential for slavery or human trafficking wherever we can do so.

4.2. Training and awareness

To raise awareness of all staff to the risk of modern slavery, particularly those

whose work is involved with at risk areas and locations, by providing training to all employees and contractors on how to identify, assess and respond to modern slavery risks.

4.3. Responsible recruitment

To ensure that all due care and attention is taken in the recruitment process to ensure there is no risk of modern slavery or human trafficking.

4.4. Supply chain due diligence 

To implement processes to screen all prospective suppliers to assess the risks of modern slavery that may arise in Enzai’s operations and supply chains.

To require suppliers to take all reasonable steps to eradicate modern slavery

in their supply chains by requiring substantive clauses on supplier obligations and expectations pertaining to modern slavery in all such contracts.

To engage in due diligence activities to identify, prevent and mitigate modern slavery risks that may arise in the company’s operations and supply chains.

4.5. Whistleblower protections

To put procedures in place to protect and empower all stakeholders to report modern slavery concerns (“Whistleblower policy”).

5. Policy principles

Enzai is committed to contributing to an inclusive and just society where people are treated with dignity and respect, where inequalities are challenged, and where we anticipate and respond positively to different needs and circumstances.

Enzai will commit the necessary resources in terms of people, time and money and effective internal arrangements to make sure that we comply with our statutory duties and that our equality scheme is implemented effectively.

6. Glossary of terms

Modern slavery: is the term used within the UK and is defined within the Modern Slavery Act 2015. These crimes include holding a person in a position of slavery , servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after.

Human trafficking: is modern-day slavery and involves the use of force, fraud, or coercion to obtain some type of labour or commercial sex act. Traffickers use force, fraud, or coercion to lure their victims and force them into labour or commercial sexual exploitation. 

Safeguarding: adults includes: Protecting their rights to live in safety, free from abuse and neglect. People and organisations working together to prevent the risk of abuse or neglect, and to stop them from happening.

Whistleblowing:  occurs when an individual raises concerns, usually to their employer or a regulator, about a workplace danger or illegality that affects others. The Public Interest Disclosure Act 1998 is the key piece of UK legislation protecting individuals who 'blow the whistle' in the public interest.

Supply chain: A supply chain is the entire process of making and selling commercial goods, including every stage from the supply of materials and the manufacture of the goods through to their distribution and sale.