Business Practices

22nd April 2024

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Waracle has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Waracle has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

As one of the UK’s leading mobile app development, IoT and digital consulting companies, Waracle understands the way your business responds to ‘being mobile’ will significantly influence your future success. We operate across the UK and Europe, with offices in Dundee, Glasgow, Edinburgh and London.

We operate a pre-employment screening policy which includes eligibility to work in the UK checks for all employees and contractors to safeguard against human trafficking or individuals being forced to work against their will.

We are a mobile app development company and therefore our supply chain includes hardware and software suppliers, contact centres, professional services suppliers and our offices employ cleaners through third party companies. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that a particular organisation has never been convicted of offenses relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

• They have taken steps to eradicate modern slavery within their business
• They hold their own suppliers to account over modern slavery
• (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate)
• (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
• We may terminate the contract at any time should any instances of modern slavery come to light]

We regularly conduct training for our staff so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This policy is reviewed annually.