MODERN SLAVERY STATEMENT

Modern Slavery and Human Trafficking Statement 2020
This statement is made on behalf of CPIT, its subsidiaries and associated businesses (collectively “the firm”) in accordance with section 54 of the Modern Slavery Act 2015 (“the Act”). It describes the steps that the firm has taken to ensure that slavery and human trafficking is not taking place in any part of our business activities and supply chains. This statement relates to the firm’s financial year ending 30 April 2020 and will be updated annually following each year end.

Firm Structure.
CPIT is an independent IT services company operating from offices in the UK & US. The firm is led by over 6 partners and employs over 100 staff. The vast majority of our staff work in the UK. Cooper Parry associated businesses include Cooper Parry IT Inc based in the United States and Dynamics Angels based in the UK.

Policies & Procedures
The firm maintains the highest standards of conduct and ethical behaviour. Our teams are aware of the actions and behaviours that are expected of them when representing the firm. We have clear employment policies and procedures in place which everyone is required to comply with. We offer regular compliance updates from internal and external sources to ensure that our knowledge remains current.

Recruitment
The firm adopts a robust recruitment process in line with UK employment legislations and is a Disability Confident employer. We recruit our talent from a wide pool and candidates may apply via direct job adverts, employee referrals or be approached by one of our recruitment team on LinkedIn.

Whistleblowing
The firm encourages all employees, partners and contractors to report any concerns they have around the conduct of others in the business and any wrongdoings they witness or suspect. Our teams can make a confidential disclosure via our Whistleblowing helpline. The helpline is managed externally via our Employee Assistance Programme. All reports are made anonymously and remain confidential. Our Whistleblowing policy gives further information. There were no reported incidents of slavery during our 2018/19 financial year.

Compliance
The firm understands the importance of running a fully compliant business operating to the highest standards. Our policies and procedures are reviewed and communicated on a regular basis. We keep our teams trained and informed via various channels to ensure everyone stays up to date with regards to Regulations, legislation and technology. Training and Raising Awareness Everyone at the firm receives mandatory Modern Slavery Training to ensure they can recognise signs of human trafficking or slavery and know what to do if they witness or suspect this. The firm is committed to ensuring our teams’ awareness. This is regularly reinforced through internal communications via the firm’s communication platforms.

Supply Chains and Due Diligence
As a provider of professional business services our supply chain is not long or complex. Key suppliers mainly relate to providers of goods and services that support the functioning of our offices such as cleaners, caterers, provision of office supplies and marketing materials, IT equipment, office fixtures and fittings, recruitment consultants and provision of travel services. We also use other professional firms on a contract basis to support client facing teams and business operations. The firm uses suppliers selected by tender or by recommendation that are believed to be reputable and ethical. As part of our approach to supply chain management we currently, and will continue to:
• undertake reviews of our current suppliers to identify those where risk may be enhanced either by the nature of the sector or territory where they operate;
• work with such suppliers to understand their own policies on modern slavery;
• carry out a robust set up process for new suppliers; and
• include in our supplier set up process a review of their own Modern Slavery and Human Trafficking policy.

Looking Ahead As part of the firm’s ongoing risk management process, we continue to review and monitor our activities and continue to assess the risk of slavery and human trafficking in our business and supply chains. The firm has not been informed of any incidents of modern slavery or human trafficking during the financial year but would investigate any allegations made should they arise. In the event of such an event occurring or an allegation being made, the matter would be initially reported to our Risk Committee to determine appropriate action.