Modern Slavery Act Statement

EFFECTIVE FROM 1st JANUARY 2022

Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labor, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. This statement relates to actions and activities during the financial year 1 January 2022 to 31 December 2022.

Emergn takes a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all of our business dealings and relationships. As a result, Emergn has committed to the development of our first Modern Slavery Act Statement. This reflects our commitment to ensuring transparency in our own operations and in our approach to combating modern slavery throughout our supply chains, in accordance with our disclosure obligations under the Modern Slavery Act.

We expect the same high standards from all of our contractors, suppliers, and other business partners, we will continue to include specific prohibitions against the use of forced, compulsory, or trafficked labor, as well as anyone held in slavery or servitude, whether adults or children, in our contracting processes, and we expect our suppliers to hold their own suppliers to the same high standards.

This statement applies to all individuals who work for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

Our business and structure

Emergn is a digital business services firm that helps some of the world’s most respected businesses develop and deliver their most promising ideas into valuable digital products and customer experiences faster. Emergn offers product innovation, enterprise transformation, experience design, product delivery, intelligent automation, and data and analytics capabilities. Through our educational platform VFQ, the industry’s only work-based learning approach to scaled digital transformation, we help global enterprises and individual learners alike build agility into their way of working and deliver value at pace.

Emergn currently operates in the following countries:

  • United Kingdom
  • USA
  • Ireland
  • Germany
  • Portugal
  • Latvia
  • Ukraine
  • Romania

Commitment

Emergn acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. We understand that this requires an ongoing review of both its internal practices in relation to its labor force and, additionally, its supply chains.

Emergn does not enter into business with any other organization, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude, and forced or compulsory labor.

Our supply chains

Emergn works with companies and institutions that we trust to help us achieve our goals. We’ve spent years building an ecosystem of technology, knowledge, business and talent partners, and suppliers. What underpins it is our shared values, ways of working, and commitment to our clients and colleagues.

Our supply chain operates across a variety of industries and jurisdictions. We are acutely aware that our supply chain covers multiple countries and suppliers, and have developed the approach outlined in “Risk assessment and due diligence processes” in response to that.

Policies in relation to slavery and human trafficking

We are a values-led organization and we have a suite of internal and external policies that set out our expectations and requirements. We monitor performance and take appropriate action where we believe suppliers, partners, or colleagues do not meet our high standards.

Our Code of Conduct

This provides clarity on the high standards we expect from everyone who works at or with Emergn. It provides a framework to ensure we do the right thing; our commitments include respecting human rights and requiring everyone we work with to operate responsibly. It serves as a guide to help us make good decisions that will ultimately demonstrate that we are trusted partners, to each other and to our customers because we do these things fairly, legally, and with integrity.

Failure to comply with this Code, and the associated policies, can result in disciplinary action, including termination, depending on the severity and impact of the action.

Each country we operate in has its own laws and regulations in relation to these topics. We abide by these (including compliance with minimum earning and employee rights legislation) when reviewing and acting on any breaches or potential breaches of this code.

Emergn core values – The Emergn Way

Emergn’s core values make clear to employees the actions and behavior expected of them when working for Emergn. Our values were developed through conversations with our people and are lived in everything we do through The Emergn Way. The principles and behaviors of The Emergn Way help us bring our values to life in a practical and pragmatic way, with each other, with our customers, with our partners, and within our communities.

We strive to maintain the highest standards of employee conduct and ethical behavior when operating and managing its supply chain.

Whistleblowing Policy

Emergn encourages open communication, feedback and discussion about any matter of importance. Emergn asks all of its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of Emergn. This would include any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Emergn’s whistleblowing procedure is designed to make it easy for workers to make confidential disclosures, without fear of retaliation.

Risk assessment and due diligence processes

Emergn is committed to ensuring that we and our supply chains are free from slavery and human trafficking, and that the necessary due diligence is undertaken to provide assurance of this. The Chief Financial and Operations Officer has overall responsibility for this area of compliance.

Although our analysis on how modern slavery and human trafficking affects our organization has concluded that this remains a low risk, we are acutely aware that this is an important area that should be always be considered as we run our business.

We set out below the due diligence processes Emergn has put in place to prevent the organization from being involved with modern slavery in any way.

Emergn partners

We work with companies and institutions that we trust to help our clients achieve their goals. We’ve spent years building an ecosystem of technology, knowledge, business, and talent partners. What underpins it is our shared values and ways of working. We build long-standing relationships with local suppliers and make clear our expectations of business behavior.

Part of our commitment to continual improvement includes working with partners and suppliers, to drive their compliance with the Act through our Code of Conduct.

Procurement

Emergn’s procurement practices incorporate processes to identify and mitigate the risk of our major suppliers’ non-compliance with the requirements of the Modern Slavery Act 2015.

Invitations to tender require suppliers to confirm their compliance with the Act and to provide a formal statement to this effect. If it is considered necessary, they will be asked to provide further assurances.

Depending on the type of goods and services being provided and the origin of the supply chains involved, further due diligence may be undertaken if necessary.

Effectiveness and assurance

Emergn does not tolerate slavery and human trafficking in our supply chains and will terminate our relationship with any partners or suppliers where there was evidence of their failure to comply with the Modern Slavery Act 2015.

Emergn is committed to a plan of continual improvement during 2022. There has been no evidence of any previous connection with modern slavery or human trafficking, either within the organization or through any of our partners, suppliers, or sub-contractors.

Although it is important to undertake due diligence with our partners and suppliers, we do not consider that it is necessary to set any performance indicators for this area. We have not so far needed to take any action against a partner or supplier. We will, however, continue to keep this under review.

Training on modern slavery and trafficking

Our people play a key role in mitigating risk within our business and supply chains, and we recognize that appropriate and targeted training is essential. Staff who work in the areas likely to be affected by modern slavery will have access to training in our procedures for ensuring that Emergn and its supply chains remain free of slavery and human trafficking.

Our Onboarding process includes The Emergn Way, requiring new joiners to read the policy we have produced and watch a video from our CEO on its importance to ensure we act with integrity, do the right thing, and behave correctly when interacting with others.

This statement has been approved by the CEO and Chairman of the Board of Emergn for the year ending 31 December 2022.

Alex Adamopoulos