This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) and applies to Bladeroom Holdings Limited and its principal operating companies Bladeroom Group Limited and ModuleCo Limited (together “Bladeroom”). It sets out the steps taken, is continuing to take and intends to take to ensure that modern slavery or human trafficking is not taking place within its business and supply chain. Bladeroom fully supports the objective of the Act, which requires businesses to set out what steps have been taken in the financial year to ensure modern slavery is not occurring in their supply chain and in their own organisation.
This statement refers to the financial year ending 31st March 2021.
Organisational Structure and Supply Chains
Bladeroom is a privately-owned international provider of highly energy efficient, modular data centres and mission-critical, technically complex, modular facilities to the Healthcare and Pharmaceutical sectors. The business is controlled by a Board of Directors and employs over 80 people in the Southwest and Midlands.
Bladeroom has successfully delivered facilities to clients in the UK, Europe, Africa, Australia and the USA. We have established key partnerships and alliances with suppliers, providers and service partners – all chosen because they actively contribute to a key aspect of our operations. We develop long term relationships with these key partners and avoid making demands that might lead to them violating human rights.
Bladeroom acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Bladeroom understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
Bladeroom operate a Whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
Business is conducted in an honest and ethical manner. Our Anti-Bribery & Corruption Policy details our zero-tolerance approach to bribery and corruption and our commitment to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. This policy applies to all individuals working for or on behalf of Bladeroom in any capacity.
Supply Chain Management
In order to fulfil its activities, the main supply chain partners of the Bladeroom are situated in the UK.
We have implemented a risk-based approach to identify, prevent, mitigate and account for how Bladeroom addresses threats of modern slavery and human trafficking. Our standard T&Cs reflect our policies and we have taken steps to assess the actual and potential human rights impacts by conducting due diligence on a sample of our direct suppliers. These suppliers have completed a survey to understand the risk of modern slavery in their supply chain and actions they are taking to address this risk. The results of the survey did not give rise to any concerns to compliance with the Act.
We have a strong culture of process improvement. The assessment and compliance of new suppliers is reviewed periodically to ensure the onboarding process remains appropriate.
Exposure to Slavery and Human Trafficking
We have considered the risk of Bladeroom being exposed to slavery and human trafficking, taking into account:
- The highly skilled nature of roles and activities undertaken within Bladeroom, and the competencies required to perform them;
- The application of our policies, including whistleblowing and anti-bribery & corruption; and
- That our supply chain operations are substantially based in the UK. As a result of the factors above and, as noted elsewhere in this statement, we deem the risk of slavery or human trafficking occurring within our business to be relatively limited.
Training and Awareness
Our people play a key role in mitigating risk within our business and supply chains, and we recognise that appropriate and targeted training is essential. During the induction process new starters receive training and education on Modern Slavery and Bladeroom policies. Ongoing training for the Senior Management Team is provided on specific basis as part of their continual professional development.
Bladeroom shall take responsibility for this statement. The statement will be reviewed and updated as appropriate.
This statement was signed by the Chief Executive on 18th November 2021, on behalf of the Board of Directors.
18th November 2021