Modern Slavery Act Statement
1. Introduction
This statement sets out Nowhere Group Limited’s (‘the Company’, ‘nowhere’, ‘we’, or ‘our’) stance on tackling and reducing the risk of Modern Slavery in the business and extended supply chain. ‘Modern Slavery’ in this statement refers to slavery, forced or compulsory labour, human trafficking, servitude, and workers who are imprisoned, indentured, or bonded.
Our purpose is to champion better work and working lives. We wholeheartedly endorse the UK’s Modern Slavery Act 2015. The requirement for transparency across supply chains is a crucially important development in tackling slavery and human trafficking.
2. Our Business and Structure
nowhere has business operations in the United Kingdom, with employees, temporary staff, consultants, associates and contractors (‘Staff’) operating on its behalf in numerous countries worldwide.
We work at the highest levels with global corporations all over the world, catalysing business critical breakthroughs, building purpose-led cultures, eco-systems of innovation and designing whole-system transformations. We operate mainly in the Management Consultancy sector; however, we are also a multidisciplinary business and combine many different roles and skills to provide a unique blend of services, virtual trainings and digital products. Our trainings and products support the consultancy services and are also licensed to external consultants and client organisations.
3. Our Policies
nowhere is ensuring that we are fully aware of the issues surrounding Modern Slavery and ensure we do not engage with it. We continually monitor who we are working with in the supply chain. We also require our Staff and all others who do business with us to comply with all applicable laws, rules and regulations. The onboarding process requires all Staff to familiarise themselves with all Company policies, and the policies themselves are reviewed annually.
4. Our Supply Chains
Our supply chain consists mainly of professional service suppliers for our products and operations including ICT, fulfilment and courier services, printing of training assets and materials, purchase of retail and promotional items, office supplies, and leasing of spaces for meeting and events. We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in Modern Slavery.
5. Due Diligence
We seek to develop and strengthen supplier partnerships based on transparency, collaboration and mutual respect. We contact all suppliers to enquire about their Modern Slavery practices prior to onboarding and review these relationships on an ongoing basis. Following our annual audit, we reserve the right to compel suppliers to take remedial action or the relationship will be terminated.
Additionally, Staff are trained to look out for Modern Slavery issues as part of the Company’s HR and IT Security training process. While procedures outlined in the Grievance and Whistleblowing policies mean that if an instance of Modern Slavery is uncovered, it is remediated appropriately. Finally, all supporting policies and procedures are reviewed annually to ensure they are up to date and aligned with new legislation and best practices.
6. Our Commitment for 2024
We are proud of our current approach, internal processes and third-party diligence to prevent Modern Slavery, however, we are conscious that as our business operations grows we will face additional risks. We will continue to ensure we do not engage with Modern Slavery through continual monitoring of our supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2024.
This statement has been approved by nowhere Directors on 1 May 2024 and signed by a director. It will be reviewed and updated every year as necessary.