Elite has a zero-tolerance approach to any form of slavery.

Anti-slavery policy statement

Working together for a better tomorrow.

This statement sets out Elite Group Limited furthermore known as “Elite” – and all subsidiary companies’ actions to understand all possible modern slavery risks related to its business activities and to implement measures that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As an initial statement, this statement relates to actions and activities during the current financial year (1st Jan 2019 to 1st Jan, 2020).

For the avoidance of doubt, Elite is unequivocally committed to preventing slavery and human trafficking in its corporate activities, and to ensure that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

Elite is a UK based Internet Services Provider and Managed Services provider, focused on delivering high-quality, high-uptime technical solutions to its customers. This involves working in partnership with our clients to create a secure, and resilient network environment to help them meet regulatory demands and ensure business continuity.

We deliver a all-inclusive range of services via a nationwide network that delivers high-bandwidth Ethernet connectivity, Data centre colocation, Cloud hosting and VoIP systems, as well as acting as an advisory body to Network Operators who require technical assistance in managing infrastructure.

Applying multidisciplinary expertise and deep industry knowledge, our Elite specialists work with predominantly UK clients from many market sectors, including central and local government, financial services, media, transport and logistics.

As a virtual service, the majority of our suppliers are those installing infrastructure, or enabling IP-VPN routes to data centres and also predominantly trade within the United Kingdom.

The following is the process by which the Elite assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

Elite operates a supplier policy and undertakes due diligence on all our suppliers. The due diligence includes a statement that each supplier is required to complete to show that the organisation:

  • complies with the Modern Slavery Act;
  • takes steps to eradicate modern slavery from their busines
  • holds their own suppliers to account over modern slavery
  • Ensures their workers receive the minimum wage and undertake robust immigration checks

We may terminate the contract at any time should any instances of modern slavery come to light.

Elite does not consider it operates in high risk sectors or locations as we only operate within the UK and rarely purchase outside of the UK.

Relevant Policies

  • Supplier/Procurement: Elite has a documented process for the sourcing and approval of third party suppliers to the organisation and has an Approved Supplier Register which documents all third party suppliers to the business. Suppliers are asked to complete an annual compliance statement to confirm their standards and compliance in quality, environmental aspects, health and safety, Modern Slavery Act, information security, equal opportunities and recruitment.
  • Grievances: Elite has a documented Grievance Procedure for the reporting of unlawful discrimination in any form.
  • Learning and Development: Elite has a Learning and Development Policy to ensure the required development of staff through communication and training opportunity.
  • Whistleblowing policy: The organisation encourages all its workers to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistle blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
  • Anti slavery policy: This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where to go for help.
  • Employee code of conduct: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • creating an annual risk profile for each supplier;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation:

  • has a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
  • reviews existing supply chains to ensure ongoing compliance.

Awareness-raising programme

As well as training ‘key’ staff, the organisation is also raising awareness of modern slavery issues by developing information for cascading and circulating in our employee newsletter known as Informed.

  • the basic principles of the Modern Slavery Act 2015;
  • how employees can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Chief Executive Officer Approval

This statement has been approved by the organisation’s Director who will review and update it annually.