Vocala LTD Modern Slavery and Human Trafficking Statement

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01/04/2021

Introduction
This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 1 April 2021 and 31 March 2022. The statement sets down Vocala Ltd’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.
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Organisational structure and supply chains
This statement covers the business activities of Vocala Ltd which are as follows:
Software Development including Voice app design and development and development of bespoke web and mobile applications.
The Company currently operates in the following countries: United Kingdom.
The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking: using a modern slavery supply chain risk assessment questionnaire to identify, mitigate and manage modern slavery and risk computations for third parties.

High Risk Activities
We look for site-specific modern slavery indicators that can indicate heightened risk, including the presence of workers who are part of vulnerable populations, a Supplier’s failure to deliver on a promised term of employment, restriction of worker movement, a Supplier’s retention of identity documents, debt bondage indicators such as charging recruitment fees, and excessive over-time requirements.

Currently no high risk activities identified in our own operations and supply chains.

Responsibility for the Company’s anti-slavery initiatives is as follows:
- Policies: Ruth Stanbridge HR Manager is responsible for creating and reviewing policies. The process by which policies are developed is looking at best practice and adapting to the needs of the company.
- Risk assessments: Ruth Stanbridge Health and Safety Manager is responsible for risk assessments in respect of human rights and modern slavery by a process of a modern slavery questionnaire to identify risks in the supply chain
- Due diligence: Ruth Stanbridge is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
- Whistleblowing policy see Appendix 5 of Company Handbook - the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
- Company Code of Conduct - The Company Handbook sets down the actions and behaviour expected of employees when representing the Company.
- Corporate Social Responsibility (CSR) Policy see vocala.co - The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.

Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes building long-standing relationships with suppliers and making clear our expectations of business partners AND/OR evaluating the modern slavery and human trafficking risks of each new supplier AND/OR invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The Management Team endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by:

Name : Robert Stanbridge
Position: Managing Director
Date: 1 April 2021
Signature: