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Modern Slavery and Human Trafficking Statement

Introduction 

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people worldwide, including many in developed countries, who are being kept and exploited in various forms of slavery. Every company is at risk of being involved in this crime through its operations and supply chain.

At Neyo, we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. As outlined in our statement, we have taken concrete steps to tackle modern slavery. 

The statement sets down Neyo’s commitment to preventing slavery and human trafficking in our business activities and the steps we have taken to ensure that there is no slavery or human trafficking in our own business and supply chains. 

We all have to be alert to risks, however small. All our employees should report their concerns, and management to act upon them.  

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 01/02/2022 to 31/01/2023. We will renew this statement yearly.

This statement is made pursuant to section 54 (1) of the UK Modern Slavery Act 2015 (“the act”) and constitutes Neyo’s Modern Slavery and Human Trafficking Statement.

Our business

Neyo is a fast-growing IT solutions company that commenced its activities in 2014. In continuation of our growth journey, we have opened our subsidiary company in Mumbai, India, in 2021. Neyo takes pride in its bespoke approach and cutting-edge methodology to comprehend the client’s IT operational needs and the challenges they face. The solution proposed by us has helped our clients achieve their operational and strategic goals through wide-scale IT implementations across nations and regions. We work with many technology vendors, including ServiceNow, BMC, AutomationEdge and Dynatrace. We also provide services including Process Consulting and Project Management.

Our clients are or can be across all continents. Also, our clients could be from any domain or industry, such as Retail, Telecom, Insurance, Finance, etc. 

The labour supplied to Neyo Ltd in pursuance of its operation will be from the United Kingdom and India.

Our supply chain

Neyo has a simple supply chain to deliver services to our clients. 

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure include due diligence of the supplier’s reputation, respect for the law, compliance with health, safety and environmental standards, and references.

We haven’t been made aware of any human trafficking/slavery allegations against any of our suppliers. If we were, we would immediately act against the supplier and report it to the authorities.

Risk Assessment

The Directors of the Company are responsible for highlighting where there may be risks within the supply chain. 

They will take into account:

  • The risk profile of individual countries based on the Global Slavery Index
  • The business services rendered by the suppliers
  • The presence of vulnerable demographic groups
  • A news analysis and the insights of labour and human rights groups

This assessment will determine our response and the risk controls that we implement.

Relevant Policies

Neyo operates the following policies for identifying and preventing slavery and human trafficking in our operations:

  • Whistleblowing Policy encourages all employees, clients and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. 
  • Our Code of Conduct policy encourages employees to do the right thing by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain.
  • Neyo is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers must demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, severe violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
  • Neyo uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due Diligence

Neyo conducts due diligence on all new suppliers during onboarding and existing suppliers at regular intervals. It includes:

  • Assessing risks in the provision of particular services
  • Auditing the suppliers and their health and safety standards, labour relations and employee contracts
  • Requiring improvements to substandard employment practices
  • Sanctioning suppliers that fail to improve their performance in line with our requirements

We require all suppliers to attest that:

  • They don’t use any form of forced, compulsory or slave labour.
  • Their employees work voluntarily and are entitled to leave work.
  • They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment.
  • They don’t require employees to post a deposit/bond and don’t withhold their salaries for any reason.
  • They don’t require employees to surrender their passports or work permits as a condition of employment. 

Awareness

Neyo has raised awareness of modern slavery issues by sending an email that is focused specifically on modern slavery to all our staff, which explains:

  • Our commitment to the fight against modern slavery
  • Red flags for potential cases of slavery or human trafficking
  • How employees should report suspicions of modern slavery

Performance indicators

Neyo will continue to review its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015 as appropriate to our risks and relationships.

This statement has been approved and authorised by: 

Name: Chirag Karnik

Position: Director

Date: 01/02/2022