Smart IT Modern Slavery Policy

1. Introduction

Smart Information Technologies Limited (the Company) makes this statement in accordance with Section 54 of the Modern Slavery Act 2015. This statement constitutes the Company's slavery and human trafficking statement.

The Company is committed to preventing acts of modern slavery and human trafficking from occurring, whether in our business or our supply chains, and we require the same standards of our suppliers. This statement will be made available upon request to all who engage with us, whether in employment or in business, so that those parties may familiarise themselves with the contents.

This statement sets out the steps that the Company have taken / will be taking 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. The Company 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.

2. Our Business & Workforce

The Company operates out of offices in the UK, Ireland and Canada. As an established provider of Odoo ERP services the Company holds Gold Partner status. We employ staff from a number of countries covering infrastructure, help desk, project management, development and functional consultants.

In the UK we employ circa 65 people across 2 sites. Our workforce is a combination of full-time and part-time permanent employees as well as contractors.

The Company's recruitment process comprises of a combination of direct recruitment, and recruitment through agencies, all of whom are licenced and reputable.

The onboarding process ensures that all employees' status to live and work in the UK are checked prior to them commencing employment. Further, all our employees are subject to an onboarding process during which employees are informed and advised of the policies and procedures that underpin the way we operate.

3. Our Policies

The Company allows all individuals who work or provide services to us the right to freely choose employment and the right to associate freely with other individuals.

Our employees all have individual and clear contracts of employment, which inform them how to terminate their employment with the Company, should they choose to do so. Equally, workers are free to choose whether to join a trade union or not.

We ensure our working practices are in accordance with the Equality Act 2010 and all employment legislation. We do not engage in forced or involuntary labour and have a zero-tolerance approach to the same, meaning we do not tolerate any of our suppliers engaging in such conduct. We require suppliers to confirm that they do not participate in any forced or involuntary labour with their workers, subcontractors, agents, or associates.

As part our induction process information on and access to our policies is provided which includes, (but is not limited to) policies on Equal Opportunities, Equality, Diversity & Inclusion, Anti-Harassment and Anti-Bullying, Grievance, Whistleblowing, Corporate Social Responsibility and Anti-Bribery and Corruption.

4. Training

The Company utilises numerous different methods of training. Most training that you will receive is on-the-job training however we do utilise more formal training (courses, assessments etc) where it is appropriate to do so.

All employees are encouraged to watch for signs of modern slavery and our senior employees are aware of the requirements to prevent slavery and human trafficking.

5. Risk

The Company considers their exposure to modern slavery to be limited however we acknowledge that elevated risk of modern slavery and human trafficking associated with engaging contractors in certain high-risk countries. The Company engages contractors operating out of Sri Lanka and India which have been identified as high-risk. As such, to mitigate these risks, the Company has implemented enhanced due diligence procedures, including:

• Conducting thorough risk assessments of all contractors operating in high-risk jurisdictions.
• Maintaining regular contact to monitor working conditions and labour practices.
• Providing training to identify and respond to potential indicators of modern slavery.

The above measures in relation to contractors in high-risk jurisdictions are in addition to the Company's internal policies and measures to ensure that we are conducting business in an ethical and transparent manner. These include:

• Operating a robust recruitment policy, including eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Operating a whistle blowing policy so that all employees know they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

6. Suppliers

The Company conducts due diligence on suppliers before entering into an agreement for the provision of goods and/or services. This includes an online search to ensure that these organisations have never been convicted of offenses relating to modern slavery.

Suppliers are required to confirm that no part of their business operations contradict the Modern Slavery Act 2015.

Any instances of non-compliance with the Modern Slavery Act, or allegation of potential modern slavery in either the Company or in relation to a Supplier would be thoroughly investigated and dealt with appropriately on a case-by-case basis. Any allegations of non-compliance should be reported to the Company's Board of Directors.