Novoville Limited

Slavery and human trafficking statement

This statement sets out Novoville Limited’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

This statement relates to actions and activities during the current and next financial year.

Novoville Limited is committed to operating all of its Group’s business activities to the highest standards of business ethics and integrity. We are committed to understanding more about modern slavery and ensuring there is no modern slavery concerns in our business or supply chain.

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

We are committed to improving our practices to combat slavery and human trafficking.

In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free, we have put in place a designated Modern Slavery and Human Trafficking Policy, to demonstrate our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the financial year ending 2020.

Organisational structure and supply chains.

Novoville Limited is a software development company operating in the broader Government Technology sector. It is based in the UK, has a branch office in Greece while having operations in other European Countries as well.

Our supply chain consists of:

• Freelance software developers and computer engineers based predominantly in the UK;
• Large and small technology suppliers based in the UK and world-wide;
• Other suppliers of business services based predominantly in the UK.

Supply chain risks

The Company’s suppliers are mostly based within the UK which has a developed culture of ethical business practice and strong labour regulation. We have therefore assessed the overall risk of the Group contracting with organisations that engage in slavery or human trafficking as relatively low. However, we have recognised that a risk in our supply chain may exists where the Company contracts with technology suppliers based outside Europe.

Acts to address risks

We are taking all reasonable levels of assurance and are undertaking the following activities on an ongoing basis to assess and address these risks:

• Conducting an internal risk assessment to identify which of the Company’s suppliers are most likely to manufacture goods or provide services in countries and/or sectors where modern forms of slavery are more likely to be prevalent;
• Consulting with those suppliers whom we have identified as presenting significant inherent risk in order to understand more about their own businesses, supply chains and the steps they have taken to reduce the risk of slavery and human trafficking;
• Reviewing the Group’s existing contractual arrangements and identifying ways these can be strengthened to further reduce the risk of slavery and human trafficking in our businesses and supply chains; and
• Providing anti-slavery training to key staff in accordance with the Modern Slavery Act 2015.

Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we have in place systems to:

• Identify and assess potential risk areas in our supply chains.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains. • Monitor potential risk areas in our supply chains.
• Protect whistle blowers.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. We have a dedicated compliance team, which consists of involvement from the following departments:

• Legal and Corporate Affairs.
• New business Development

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. We also advise our business partners to provide training to their staff and suppliers and providers.

This statement was approved by the board of Novoville Limited on 1 May 2022.

Signed By,

Iraklis Bourantas
Director
Novoville Limited