HaloCRM Modern Slavery Statement

HaloCRM Modern Slavery Statement

This statement is made and published jointly on behalf of (1) Halo Service Solutions Ltd, a limited liability partnership registered in England, (2) Halo Service Solutions Ltd’s wholly-owned subsidiary, Halo Service Solutions Ltd, (3) Halo Software Solutions Australia Pty Ltd, a general partnership constituted under the laws of the Australian Capital Territory.

Overview

Halo Service Solutions is one of the UK’s fastest growing software companies, based in Stowmarket, Suffolk. Halo Service Solutions started out with a single all-in-one business solution, run by 2 individuals in 1994. This was built upon over time based upon clients demands, presenting a unique opportunity for Halo Service Solutions to innovate new solutions to real-life business problems. Now, Halo Service Solutions offer 3 individual products rooted in sector best practise, as well as professional services. The company also has a global reach, with users in over 60 countries and 2 offices in Australia and the USA. These products are still constantly evolving to be on the cutting edge of ITSM tools.

We wholeheartedly support the Modern Slavery Act 2015 (UK) and the Modern Slavery Act 2018 (Cth) (Aust) whose provisions assist to eradicate modern slavery, wherever it may occur, and raise public awareness of the problem. In addition to working to prevent modern slavery in our own supply chains, Halo Service Solutions Social Impact Team is also working with a range of partners to support a wide range of initiatives to eradicate all forms of modern slavery around the world.

Our Approach

We are committed to achieving the highest standards of ethical behaviour in the conduct of our business and activities worldwide. We support and respect the protection of internationally proclaimed human rights and endeavour to make sure that Halo Service Solutions is not complicit in human rights abuses. To this end, we will not tolerate slavery or human trafficking or abusive or unfair treatment in any part of our own business or in any of our supply chains. We are generally, and in particular through our policies and practices in relation to procurement, people and culture and corporate responsibility, committed to taking steps to ensure that slavery and human trafficking play no part in our own business or in our supply chains.

Our Operations and Supply Chain

Our supply chains consist primarily of the provision of or office facilities, which support our staff
in their work. The key components they supply us with are:

• Technology: such as IT hardware and software and print services that support our business.
• Business services: the products that we buy into our offices, for example furniture, stationery and marketing items as well as the services that we use in our offices such as catering, security and cleaning.
• Travel services: organising and booking our travel and accommodation requirements.

We believe there is no risk of modern slavery in our directly employed workforce, as the labour market in Australia is highly regulated, strict regulations apply to the Information Technology sectors, and the presence of unions who represent employees by negotiating employment conditions. Our whistleblower policy and procedure details processes and communication pathways for employees, and suppliers, to disclose misconduct in our business and supply chain without recrimination.

Our supply chain

A significant number of our supplier’s operations are based in Australia. We believe these suppliers have a lower risk of modern slavery occurring in their supply chains, as their operations are Australian based, they are required to comply with the Modern Slavery Act within their own supply chains. However, our procurement activities do include purchasing goods and services from suppliers who provide potentially high risk products, such as, laptops and uniforms. To establish an initial baseline understanding, for our first year of modern slavery reporting, we mapped out our key suppliers and service providers. This enabled us to undertake a risk assessment of any modern slavery risks, or potential risks, within our supplier’s operations and supply chains. We identified a number of high-risk suppliers who are either located in or source their goods from high risk countries, for example, the procurement of uniforms from suppliers who have manufacturing plants overseas. High risk suppliers were requested to
complete a Modern Slavery Supplier Questionnaire. The responses we received from our identified high risk suppliers indicated they have implemented adequate steps to mitigate modern slavery risks, their responses also indicated that their organisations required that their supply chains follow an ethical sourcing policy. The results of the Modern Slavery Supplier Questionnaire did not indicate the need for any further actions at this point in time.

Our Governance Framework

Halo Service Solutions has a strong corporate governance framework and as part of our commitment to informing our employees and suppliers in modern slavery risks, we undertook a review of our standard procurement agreements and procurement processes to ensure that we have sound governance processes in place to meet our modern slavery compliance. In summary our review included the following activities:

• Publication of our Modern Slavery Policy;
• Update of our tender documents to include the Modern Slavery Supplier Questionnaire to ensure we identify modern slavery risks early with new suppliers during the procurement process;
• Review of our procurement policy and procedures to ensure inclusion of modern slavery clauses; and
• Update of our standard procurement agreements to include contractual obligations to address
  modern slavery compliance so that all new suppliers commit to adherence to the new modern
  slavery requirements.

Awareness Raising Programme

Halo Service Solutions aims to raise awareness and strengthen our understanding of the risk of
modern slavery within our business and our supply chain by:

• Employees: Online Education Learning Module – developing an annual online education tool to provide employees information on and their role in eliminating modern slavery in our workplace and our supply chain.
• Suppliers: Halo Service Solutions online induction program will be updated to include the following:
  o Pre-qualification section: Modern Slavery Supplier Questionnaire will be uploaded for completion by suppliers; and
  o Supplier employee registration section: introduction of a modern slavery education toolkit that will be completed as part of Halo Service Solutions requirements that all supplier’s employees complete the online induction annually.

Corporate Governance

Halo Service Solutions will continue to review our policies and procedures to ensure that we have sound governance processes in place to meet our modern slavery compliance requirements. Halo Service Solutions will conduct reviews of policies, such as, our Code of Conduct and Whistleblower, to ensure inclusion of modern slavery clauses to increase employee awareness of the risks of modern slavery in our business and our supply chain.

Questions

If you have any questions about this statement, please send an e-mail to andrew.chipchase@imaginehalo.com and we will respond in accordance with our standard service level agreement.