MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT.

A statement addressing the UK Modern Slavery Act

JUNE 2024.

This statement complies with the United Kingdom Modern Slavery Act of 2015 which requires large retailers and manufacturers to disclose their efforts to eradicate slavery and human trafficking from their supply chain. In response, this statement reflects Go Inspire Group Limited, a Xerox Company’s efforts to combat the conduct that precipitates such crimes in our supply chain. This statement provides both current and potential customers the ability to make well-informed choices about the products and services they purchase.

Organisational structure.

This statement covers the business activities of Go Inspire Group Limited and its subsidiary companies. Go Inspire Group Limited is a company incorporated in England and Wales with registered number 09903285.  The registered office is at 147 Scudamore Road, Leicester, LE3 1UQ.

Go Inspire Group Limited is a leading integrated direct marketing and multi-channel customer communications provider. We offer a complete service from customer insight, strategy and targeting development, to campaign execution and management with creative print and mail, and response capture.

The head office is based in the United Kingdom with no international offices or presence.

Go Inspire Group Limited was acquired by Xerox in July 2022 to become a Xerox Company.

Statement.

The business operations of any company have the potential to affect the human rights of its stakeholders. Go Inspire Group Limited is committed to identifying those impacts and mitigating or minimising the risk. Examples of such impacts include discrimination, violence, loss of the right to freedom of expression and collective bargaining in workplaces; child/forced labour and human trafficking in the supply chain.

At Go Inspire Group Limited, we are deeply committed to the eradication of modern slavery and human trafficking in all its forms, as mandated by the Modern Slavery Act 2015.

Go Inspire Group Limited is committed to freely chosen employment, in our position on labour relations in our employment practices, and in our relationships with suppliers. Go Inspire Group Limited principles are guided by the United Nations Universal Declaration of Human Rights and the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work which prohibits forced or compulsory labour and child labour.

We acknowledge that modern slavery and human trafficking are significant global issues that require collective action and vigilance. Therefore, we remain dedicated to implementing robust policies, procedures, and practices aimed at preventing and addressing any instances of exploitation within our sphere of influence.

Go Inspire Group Limited approach to Modern Slavery is also guided by Xerox’s Human Rights Working Group. The Human Rights Working Group considers the effectiveness of the program, the nature of the risk environment, and evolving best practices. As appropriate, the Human Rights Working Group recommends changes to the program. The Human Rights Working Group regularly engages internal and external stakeholders to understand best practices and determine how they can continually improve this program.

Supplier Relations and Controls.

In general, the greatest potential risk of slavery and human trafficking can exist in supply chains. Go Inspire Group Limited believes that the risk of slavery and human trafficking is mitigated by clearly established standards, oversight and quality controls within Go Inspire Group’s sourcing process, social compliance verification process and business operations.

To strengthen our approach to supplier-facing sustainability and human rights actions, our parent company, Xerox, started working with the Electronic Industry Citizenship Coalition (now known as the Responsible Business Alliance or RBA) in 2006 and became a member in 2008. Xerox are actively involved in advancing industry-wide responsible practices through their engagement in the RBA.

Go Inspire Group Limited are dedicated to respecting the rights and promoting well-being of workers and communities engaged in the global supply chain. Go Inspire Group Limited is committed to continuously improving the social, environmental, and ethical responsibility of its supply chain.

Go Inspire Group Limited has implemented a Supplier Code of Conduct for its suppliers to adhere to. The Supplier Code of Conduct includes labour standards based on recognised principles of international labour and human rights. Freely chosen labour is a primary standard in the Supplier Code of Conduct, prohibiting forced, bonded, or indentured labour.

The following highlight our efforts to eradicate forced and compulsory labour, and child labour from our supply chain:

Verification.

Go Inspire Group Limited takes several steps to verify, evaluate, and address risks of slavery and human trafficking in our supply chain.

Go Inspire Group Limited sets clear expectations with all of our suppliers who provide direct materials and services, which includes the prohibition against forced or compulsory labour and child labour. Our supplier on-boarding documentation contain language in which suppliers must affirm their commitment to comply with all provisions of the Supplier Code of Conduct.

We recognise an obligation to actively manage our supplier base and ensure these critical partners meet our high social, environmental, and ethical standards and to ensure the Supplier Code of Conduct is being adhered to.

Go Inspire Group Limited conducts initial risk assessments of its suppliers based on location, foreign worker population and other business and supply assurance and risk-based criteria.

For those suppliers identified in the initial risk assessment as high-risk, the supplier is either required to complete a self-assessment or is audited by Go Inspire Group Limited. The supplier’s responses allow Go Inspire Group Limited to identify where possible risks in the supply chain exist. If significant risks are identified, an announced audit of that supplier is conducted. We also aim to raise suppliers’ awareness about the importance of social responsibility topics, clarify our expectations, target areas for review, and document suppliers’ assessment of their performance.

Audit.

As indicated above, if major risks are identified, an announced audit of that supplier is conducted.

We actively continue to work with our direct suppliers to flow down our required standards to address risks for modern slavery or human trafficking.

During the audit process, areas of non-conformance are evaluated and classified based on risk level and priority and are remediated through a corrective action process.

The audit is used to evaluate key critical sustainability areas, including but not limited to, labour practices, freedom of association, child labour, forced labour, human rights, recruitment, passport seizure and environmental concerns.

Certification.

Go Inspire Group Limited requires all suppliers to represent and warrant their compliance with all applicable laws and regulations.

Go Inspire Group Limited screen all suppliers to ensure compliance with global anti-bribery laws and regulations, including but not limited to, the U.K. Bribery Act. If a supplier is found to have violated applicable laws or contract terms and conditions, Go Inspire Group will review each situation on a case-by-case basis and determine the necessary course of action (i.e., terminate supplier relationship, instruct supplier to make corrective actions, etc.).

To ensure full compliance, critical suppliers are required to keep the following business documents, where applicable, on file while conducting business with Go Inspire Group Limited:

Go Inspire Group Purchase Orders and Supplier invoices

Confidentiality / Non-Disclosure Agreement

Business Continuity / Disaster Recovery Plans

Health, Safety and Quality Plans

Information Security Plans

Responsibilities.

Responsibility for Go Inspire Group’s modern slavery and human trafficking initiatives is as follows:

  • The Group Senior Leadership Team and HR Department holds the responsibility for establishing and reviewing policies concerning modern slavery and human trafficking. These policies are developed through a thorough examination of best practices and are tailored to suit the specific requirements of Go Inspire Group.
  • The Group HR Department is responsible for conducting due diligence concerning identified or suspected cases of modern slavery and human trafficking.
  • The Group Transformation Director also heads up the sustainability programme to facilitate further commitment to business operations and practices.

 

Whistleblowing.

At Go Inspire Group Limited, we encourage a culture of transparency and accountability. We are committed to providing channels for reporting any concerns or suspicions regarding modern slavery and human trafficking, as well as other ethical breaches.

Employees, suppliers, customers, and other stakeholders are encouraged to speak up and report any instances or suspicions of wrongdoing without fear of retaliation.

We take all reports seriously and will investigate them promptly and impartially.

Confidentiality will be maintained throughout the process, and appropriate action will be taken in line with our policies and legal obligations. We are dedicated to fostering an environment where integrity and ethical conduct are valued and upheld by all.

Credible information regarding a potential violation of this anti-human trafficking policy, whether by an employee, subcontractor, or other party, must be promptly reported to a manager, director, or HR department.

If a specific case of modern slavery is identified in the UK, it should be reported to the police immediately on 101. If potential victims are in immediate danger the standard 999 emergency number should be used.

TRAINING.

All Go Inspire Group employees are required to complete training on modern slavery awareness on an annual basis. The training is designed to enhance an employee’s ability to recognise and respond to issues and understand the expectations about reporting suspected violations.

Communication.

As part of our commitment to transparency and accountability, this statement will be published on our company website and communicated to all stakeholders. We invite feedback and collaboration from our employees, suppliers, customers, and other stakeholders as we work together to eradicate modern slavery and human trafficking from our communities and beyond.

Review.

This Modern Slavery and Human Trafficking Statement will undergo regular reviews and updates as required. The Senior Leadership Team fully supports and endorses this policy statement and is wholly dedicated to ensuring its effective implementation throughout the business.

Approval.

In accordance with the U.K. Modern Slavery Act 2015 and guidance thereunder, this 2024 statement on efforts to prevent modern slavery in our business and supply chains was approved by the Group Managing Director of Go Inspire Group Limited.

Name: Dimitri Kyprianou
Position: Group Managing Director
Date: June 2024

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