Executive summary

This Modern Slavery Statement sets out the actions taken by TEK HEADQUARTERS LIMITED (TEKHQS) during our financial year from 1 July 2022 to 30 June 2023 (‘FY23’) to prevent modern slavery occurring within our operations or supply chains and has been prepared in accordance with section 54(1) of the Modern Slavery Act 2015. 

No instances of modern slavery have been identified in our operations or supply chains during FY23.   

We have made further progress with our anti-modern slavery initiatives this year and have met the key aims for FY23 that were set out in our 2022 Modern Slavery Statement, as follows: 

1. Providing further training to higher-risk and higher-spend suppliers on human rights and modern slavery risks, and the standards required under our Supplier Code of Conduct. 
2. Reviewing our purchasing practices to ensure that we are not putting undue pressure on suppliers that may increase the risk of human rights issues.
3. Publishing and promoting our new Modern Slavery Policy and Response Plan within our business and carrying-out an expanded training programme for key teams who are responsible for implementing measures to identify or mitigate modern slavery occurring. 
4. Taking steps to embed human rights risk factors into our client acceptance process, including releasing a new UK Client & Engagement Acceptance Addendum policy to our existing Global policy, which put a mandatory requirement on our people to perform additional research on all clients, including adverse environmental, social and governance (ESG) media outcomes. 

We have set key aims for FY24 to ensure that our anti-modern slavery initiatives continue to progress and we have taken further steps to identify and address modern slavery risks within our operations or supply chains. 

Our purpose is building a better working world. Our anti-modern slavery initiatives are part of our wider corporate social responsibility and sustainability goals that help achieve this purpose. 

About us

A world of expertise and knowledge. Over a decade of experience serving different industries to develop and maintain impactful, transformational IT systems and “insight” generating data infrastructure.

“Tek Headquarters” has grown year on year with clients, employees and consultants worldwide. We have offices and partners in USA, UK, Sweden, UAE, Pakistan and India.

Tek Headquarters has been certified by BSI to ISO 9001 Quality Management and ISO/IEC 27001 Information Security Management. We also hold the Cyber Essentials certification and are part of the Disability Confident Committed scheme.

Additionally, we have a strong team of Microsoft, SAP and Oracle Certified team members within our organization.

Our operations

The TEKHQS UK business operates primarily in the technology sector, providing products and services that require significant intellectual input from skilled workers. Our supply chain includes hardware manufacturers, software development partners, and data center operators across various countries.

Policies and compliance

Our policy applies to all TEKHQS personnel across the globe and sets out the basis of our culture of acting ethically and in accordance with the highest professional standards. It makes it clear that all our people have a duty to take the most ethical course of action in any given situation and to report any behaviour which is inconsistent with the principles. All TEKHQS personnel are required to sign an annual declaration to confirm that they have read, understood and are in full compliance with the Code. 

Our UK Modern Slavery Policy applies to all TEKHQS personnel in the UK and has been revised this year. The policy sets out guidance as to what modern slavery is, how to spot

and report potential instances of it and explains how our people are required to take individual responsibility for implementing our anti-modern slavery controls by:

• Reporting any suspected instances of modern slavery. 
• Adhering to the relevant procurement procedures when procuring goods or services from external suppliers. 
• Ensuring that our client and engagement acceptance measures relating to ESG are followed when considering new client relationships or engagements. 
• Following our policies in relation to the recruitment and treatment of employees and contractors. 

We also published our Modern Slavery Response Plan this year, which sets out how the firm will handle any reported concerns of Modern Slavery. This defines the investigation process that the firm will follow, the further escalation and reporting measures that apply, and guidance as to potential remedial actions to help ensure the safety of potential victims of modern slavery. 

The firm’s Safeguarding and Prevent Policy sets out guidance as to how our people can help ensure that minors and vulnerable individuals are protected from harm or abuse, which includes how to recognise and report potential instances of, amongst other things, Modern Slavery. 

Reporting concerns

Our Modern Slavery Policy, Modern Slavery Response Plan and Safeguarding Policy each contain guidance on how to report any concerns that our people may have about modern slavery. There are various methods that our people can use to raise concerns, including: 

• By emailing our dedicated modern slavery mailbox, which is monitored by a team. 
• By contacting our Help HR mailbox, helpline or chat messaging facility. 
• By contacting an appropriate manager.  
• By using Culture Shift, our internal helpline for raising cultural concerns.

During FY23, no complaints or concerns were raised about modern slavery or human trafficking to the firm.

How we address key risks within our operation

We set high standards for ourselves and take positive action to ensure that modern slavery does not take place in our business. As a professional services firm, we are lower risk than some organizations but we remain vigilant to potential risks. We have identified

the potential areas where risk might arise in our internal operations and taken steps to minimize that risk to the best of our ability, in line with our code and values.

It helps our Recruitment team to identify any potential red flags for possible modern slavery, and any discrepancies or irregularities will be followed up.

Whilst there have not been any instances or suspicions of modern slavery identified or raised, in the event such concerns were raised, we have a comprehensive framework in place to investigate and ensure appropriate action will be taken.

• Acquisition due diligence – Our Risk Management and Talent teams carry out enhanced due diligence in respect of any entity that the firm is targeting for acquisition. This assessment includes a review of any modern slavery risks in respect of new personnel joining our firm as a result of the acquisition but also extends to identifying risks within the target’s suppliers and business relationships.  
• Encouraging people to speak up – We encourage people to raise any concerns about potential breaches of our Code of Conduct or values, or any other ethical matters, to anybody within the organization – and they can feel confident that this will be taken seriously and with due sensitivity. This encouragement comes from regular communications from senior leaders, as well as focused training to our people.  

Due Diligence Processes

To identify and mitigate risk areas in our supply chains, we:

• Conduct regular audits of our suppliers to ensure compliance with company standards, including labor rights protections.
• Require all key suppliers to confirm that they comply with our Modern Slavery Policy.

Training

We provide training to our staff, particularly those who directly manage supply chain relationships, to ensure they understand the risks associated with modern slavery and human trafficking and how to mitigate them.

Assessment of suppliers

We carry out ESG-specific due diligence prior to engaging with suppliers and require all potential suppliers to complete a core set of Request for Proposal (RFP) questions and provide appropriate evidence in relation to the ESG (including human rights and modern slavery) risks within their business and supply chain, the due diligence that they have carried out in relation to their vendors and the measures and safeguards which they have in place to prevent modern slavery occurring.   

Our sourcing managers also make use of our Sustainable Sourcing Framework to understand the potential ESG risks associated for particular products and services and the framework contains additional specific RFP questions to be asked to help assess the suitability of the supplier, particularly where the product or service sits within a higher-risk area for ESG issues (including modern slavery). This process helps us to make even better-informed decisions about the supplier that is chosen for the sourcing project. 

Our next steps

To ensure that we continue to assess and develop our anti-modern slavery strategy and measures, we have the following key aims for FY24: 

1. Expand our internal Modern Slavery Training programme and provide targeted training to further areas of our client-facing business. 
2. Further develop our Modern Slavery Risk Assessment and Key Risk Indicators to facilitate enhanced insights and reporting on modern slavery hotspots, issues and initiatives, to reach senior leadership across the firm.  
3. Prepare and launch a dedicated modern slavery area on our intranet, to ensure that all of our anti-modern slavery tools, resources and information are easily accessible to our people and to help raise further awareness of modern slavery issues within our business. 

Responsibility

TEKHQS has overall responsibility for our modern slavery policy and for ensuring that all those under the firm’s control comply with it.

Our management has primary and day-to-day responsibility for implementing our modern slavery policy, monitoring its use and effectiveness, dealing with any queries about it and ensuring the firm’s internal control systems and internal auditing procedures are effective in countering modern slavery and human trafficking within our business and supply chain. 

The firm remains committed to improving its practices to combat modern slavery and human trafficking. 

Syed, Mazhar | Director

TEK HEADQUARTERS LIMITED

12 December 2023