HSO approach to Modern Slavery and Human Trafficking

This statement is published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by the HSO group of companies to prevent modern slavery and human trafficking in its business entities and supply chains.

Our Anti-Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere.

HSO Policy Statement

HSO Enterprise Solutions Limited, a company incorporated under the laws of England and Wales under company number 9910591 are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our businesses and expects our suppliers and customers to uphold the same zero tolerance standard regardless of the nature, scale, or jurisdiction of their business.

Our business structure and supply chain

HSO is a business transformation partner, providing companies with deep industry expertise and global reach. We leverage the full power of Microsoft technology to transform how our customers work and improve their business performance.

HSO has offices in the UK, Europe, North America, Asia Pacific, and Oceania and provides services globally. Each of HSO entities operate with its own local management team in each jurisdiction, reporting into HSO Group Head Office located in Europe.

HSO partners exclusively with Microsoft to deliver against its mission and is also a Microsoft Inner Circle Partner. The industries we operate in are Manufacturing, Financial Services, Professional Services, Retail, Public Sector and Non-Profit.

Our suppliers and contractors include professional service providers, technical support, property maintenance and facilities management.

HSO Holding Ltd entities covered by this policy are:

In this statement, the term ‘HSO Holding Ltd’ refers to all individual specialist companies, legal entities and HSO subsidiaries globally.

This statement has been published in accordance with the UK Modern Slavery Act 2015 but extends to all entities in differing jurisdictions, including those with existing or emerging laws whereby we expect the highest ethical standards across our business and supply chains at all times. The UK Modern Slavery Act 2015 is a globally leading piece of legislation that we take guidance by across our global business.

Due Diligence Process

We make sure that we base our supplier selection on an objective and fair criterion that also includes consideration of environmental, social, and ethical performance. Before being engaged to provide any goods or services to any part of our business, a potential supplier provides us with:

Confirmation that no instances of modern slavery or human trafficking has occurred.
Information about the steps they take to ensure that no modern slavery or human trafficking has occurred within their own supply chain.

We endeavour to comply with all national and international laws, trade restrictions, embargoes, sanctions, and regulations that apply to the work we do. We are committed to respecting the dignity, liberty, and equality of everyone we work with. This includes maintaining an interest in the business practices used by companies and business partners that supply goods or services to us.

Risk Assessment and Management

In exercising supplier due diligence, we use a risk-based approach to ensure we focus on those areas where the risk is greatest and maximum impact can be achieved. We consider the risk of modern slavery or human trafficking occurring within our supply chain to be low. The principal reasons for this are:

The majority of our suppliers are large organisations with robust and sophisticated policies and processes.

Many of our customers operate in industries with a high degree of independent regulatory scrutiny.

HSO incorporates express contractual obligations within our standard terms and conditions of business with regard to modern slavery and human trafficking.

However, if we identify a supplier or potential supplier with a higher risk characteristic in relation to modern slavery and human trafficking, they will be subjected to a higher degree of scrutiny. Characteristics indicating a need for enhanced scrutiny may include, but are not limited to:

• The smaller scale of the supplier or client business, meaning less advanced internal policies.
• The operation of manufacturing or processing facilities in a country with higher levels of modern slavery exposure.
• A supplier or customer reliance on supply chains with considerable geographic or operational complexity resulting in challenges in monitoring relevant policies.

Effectiveness

At no time since its formation has HSO encountered or been the subject of any allegations or complaints of any occurrence of modern slavery or human trafficking within its business or supply chain.

We acknowledge that we have a continuing obligation to ensure that our relevant policies and strategies remain fit for purpose as the scale of our business and operations develop over time.

Employee Awareness and Training

As part of our initiative to identify and mitigate risk we operate a range of policies and procedures appropriate to our businesses which all staff are trained on in their induction. These include policies and procedures in relation to anti-slavery and human trafficking.

HSO also operates a Whistleblowing Policy, demonstrating our commitment to reducing any unethical practices. This policy facilitates an independent reporting service available to all employees, customers, officers, consultants, contractors, casual workers, and agency workers who may experience or witness unethical behaviour or practices.