Anti-slavery and human trafficking policy statement

Introduction from the Chief Executive Officer

Modern Slavery is an umbrella term to refer to situations of exploitation that an individual cannot refuse or leave because of threats, violence, coercion, deception, or abuse of power.

We are committed to complying with all applicable international human rights standards, labour and employment laws, rules and regulations, and working to mitigate the risks of modern slavery and human trafficking in our business operations and supply chains.

This statement covers the period 1 April 2021 to 31 March 2022, in compliance with the UK’s Modern Slavery Act.

This statement assesses our risk, outlines our efforts and sets commitments for the coming year.


Section 1. Organisational structure, operations and supply chains

Founded in 1995, Bell Microsystems Limited (“BML”) has two main businesses:

  • Systems integrator (trading as “Bell Integration”) delivering IT hardware and IT services, consulting and supporting organisations to develop the workspace that suits their needs by providing flexible and innovative solutions to help them move to up to date IT services and to streamline their operations.
  • Procurement management services (trading as ‘Bell Procurement Management’) including the sale of deliverables to its customers purchased from its vetted supplier base located predominantly in Europe and the Asia Pacific region.

As of 31 March 2022, BML:

  • Employed 567 full and part time workers across the globe.
  • Bell Procurement Management onboarded almost 2,000 new suppliers in this period.
    More information can be found about Bell on our website.

Our supply chains in the last financial year

Bell Integration

  • Last year, Bell Integration spent more than £598 million with over 6000 third party suppliers from 41 countries.
  • The majority of Bell Integration’s direct suppliers (tier 1) are registered in Europe.

Bell Procurement Management

  • Last year, Bell Procurement Management spent approximately £208 million with over 300 third party suppliers in 18 countries (mostly in the UK, Australia and New Zealand).
  • The majority of Bell Procurement Management direct suppliers (tier 1) are registered in low risk countries but some of their operations and supply chains are global.

 

Section 2 – Policies on modern slavery

In September 2021, we announced and commenced a review of our procurement and social media policies to outline the due diligence that must be conducted at each stage of the procurement process and to support Bell’s stance on the ability of anyone to enjoy the human right to freedom of speech and to engage in critical and free enquiry.


Section 3 – Risk Assessment and Due diligence

Based on the nature of our business, we consider the risks of modern slavery and human trafficking to be low in our direct business operations.

However, we are aware that inherent and potential risks of modern slavery and human trafficking could be present in our supply chain, and we recognise that we have a role to play in the global effort to eliminate modern slavery and human trafficking.

Suppliers go through an onboarding process in which they are asked to comply with a minimum set of requirements in order to be included in our supplier base. This includes financial due diligence and acceptance of Bell’s Supplier Charter.

Bell is registered as a supplier in the Trust Your Supplier platform which enables organisations to use a common industry approach to review risks, including human rights, when on-boarding suppliers. This platform provides access to supplier information that is verified by third parties using blockchain technology.

In the last year, we compiled a register of Bell corporate suppliers and conducted a risk assessment of all Bell Procurement Management suppliers (including all strategic and principal suppliers) and developed a risk-based questionnaire/screening tool to be used by procurement teams when undertaking future procurements to assess modern slavery risks.

Whilst instances of modern slavery were not identified in Bell’s operations and supply chain for the period of this report, Bell intends to work with any parties found to have instances of modern slavery in their operations or supply chain by providing education, guidance, and assistance as required.

No whistleblowing complaints were received.

 

Section 4. Training and awareness raising

Increasing the skills and capability of our people is fundamental to our ability to conduct effective modern slavery due diligence on our supply chains.

Training is delivered through e-learning courses, face-to-face line manager events, webinars, and induction programmes for new employees.

As at 31 March 2022, 82% of active employees have completed the e-learning training in Modern Slavery.

We expect all our suppliers to operate in a responsible, ethical, open, and transparent way and in compliance with all applicable laws and regulations. Our global teams work closely with suppliers to communicate our standards and help suppliers build their capacity to provide working environments that are safe, respectful of human rights, and free of modern slavery.

 

Section 5. Key performance indicators to measure effectiveness of steps being taken

In September 2021, our performance on environmental, social and governance matters was recognised by a Gold EcoVadis assessment for the Bell Procurement Management business (an independent sustainability ratings agency providing transparency into an organisations’ sustainability practices).

Since its launch in July 2021 100% of applicable suppliers have accepted the terms of Bell PM’s supplier charter.

Bell seeks to continuously improve its own purchasing practices. We understand that we can have a profound impact on the conditions of workers in supply chains through our own purchasing practices. Aggressive pricing, short lead times and late payments are just a few examples of purchasing practices that can unintentionally create modern slavery risks.

We want to make sure we pay our suppliers promptly and our suppliers do the same in their supply chains. In the financial year 2021-22, we paid 87% of compliant Bell Procurement Management supplier invoices within 30 days and 95% of compliant supplier invoices within 60 days.

 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. This Statement has been approved by the board of directors of Bell Microsystems Limited and its relevant subsidiaries on 23 June 2022.

Manpreet Gill

Director

23 June 2022

 

Download the Anti-Slavery Policy Statement