Modern Slavery Statement

1. Why this statement exists, and why it is voluntary

Section 54 of the Modern Slavery Act 2015 requires a commercial organisation that supplies goods or services and has a total turnover of not less than a prescribed amount to prepare a slavery and human trafficking statement for each financial year. Regulation 2 of the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 prescribes that amount as £36 million, calculated as the organisation's turnover together with that of any subsidiary undertakings.

[TeamTalk Ltd] is below that threshold and is therefore not required by law to publish a statement. It publishes one anyway, because supplier onboarding forms in construction, contract catering and facilities management ask for one regardless of turnover, and because a supplier that cannot answer the question delays its customer's procurement. This statement is made in the spirit of section 54 and follows the structure that section 54(5) suggests, without asserting a legal status it does not have.

2. Our structure, business and supply chains

[TeamTalk Ltd] is a private limited company registered in England and Wales, company number [number], with [N] employees and [N] contractors, operating solely in the United Kingdom. It develops and supplies TeamTalk, a software service that delivers workplace notices to frontline workers in their own language and records confirmation of receipt.

The company has no manufacturing, no physical products, no warehousing, no logistics and no operations in any high-risk jurisdiction. Its supply chain is short and consists almost entirely of business services purchased under the suppliers' own standard terms: cloud hosting and storage; communications, video and translation services; software subscriptions; professional services such as accountancy, legal and insurance; and occasional print for customer materials. Its largest single exposure to labour risk is not in its own supply chain but in the workforces of its customers, who are precisely the organisations this product helps to reach.

3. Our policies

• Slavery, servitude, forced or compulsory labour and human trafficking are not tolerated in any part of the business or its supply chain.
• Everyone engaged by the company has a written contract, is paid at or above the National Living Wage or National Minimum Wage as applicable, is paid directly into a bank account in their own name, and holds their own identity documents. The company does not retain original identity documents.
• Right to work checks are carried out for all employees before they start.
• No recruitment fee of any kind is charged to a worker.
• The company does not use labour providers, gangmasters or unregulated recruitment intermediaries. If it ever does, it will verify licensing with the Gangmasters and Labour Abuse Authority first.
• Anyone may raise a concern about modern slavery, in confidence and without any detriment, to [name, email, mobile]. Concerns may also be raised anonymously and, where a concern relates to a customer's or supplier's operations, will be escalated to that organisation and, where appropriate, to the Modern Slavery Helpline on 08000 121 700.

4. Due diligence and risk assessment

The company assesses its modern slavery risk as low, on the basis that it employs a small number of skilled workers directly in the United Kingdom, uses no agency or subcontracted manual labour, and buys services rather than goods. That assessment is reviewed annually and is not treated as a conclusion that no action is needed.

In practice the company:

• reviews the published modern slavery position of every material supplier before engagement, and prefers suppliers that publish a statement;
• includes an anti-slavery obligation in its own customer and supplier contracts, requiring compliance with the 2015 Act and reasonable steps to keep slavery and trafficking out of the counterparty's supply chain;
• does not knowingly contract with any organisation that has been found to have used forced labour, and reserves the right to terminate where it discovers that it has;
• records the outcome of these checks with a date, so that the answer to a customer's question is evidenced rather than asserted.

5. Effectiveness and training

Because the company is small and its supply chain is short, effectiveness is measured on a small number of honest indicators rather than an elaborate framework: the proportion of material suppliers whose modern slavery position has been reviewed in the last 12 months [target 100%]; the number of concerns raised and their outcome [nil to date]; and whether the anti-slavery clause is present in every signed supplier and customer contract.

All personnel receive a short briefing on modern slavery indicators and on how to raise a concern, on joining and annually thereafter. Given that the company's customers operate in construction, catering and facilities management, where labour exploitation risk is materially higher, personnel are also briefed on what to do if they observe something of concern while visiting a customer site: report it to the site's responsible person and to the director named in this statement, and, where there is a risk to life, to the police.

6. Approval and publication

This statement covers the financial year ending [date]. It is approved by the board of [TeamTalk Ltd] and signed by a director, and is published on the company's website at [URL] with a link in a prominent place on the homepage, following the form that section 54(6) and 54(7) require of organisations that are in scope. The company [has / has not] also submitted it to the Home Office modern slavery statement registry, submission to which is voluntary and open to organisations of any size.