Credera Limited Statement on the Modern Slavery Act
5th May 2023
This Statement is Credera Limited’s Modern Slavery Statement (the “Statement”) and covers the period of 1st January 2023 to 31st December 2023 (“Reporting Period”).
Credera is committed to respecting human rights and believes there is no place for modern slavery within the operations of any ethical business. We are joining the challenge to combat modern slavery by working to guard against this practice in our own supply chains and operations.
Modern slavery refers to cases of serious exploitation, including where offenders use coercion, threats, or deception to exploit victims and undermine their freedom. Modern slavery impacts men, women and children and includes situations where individuals are forced to work against their will under threat.
This Statement applies to Credera Limited and any listed subsidiary entities. The Statement has been produced in accordance with Australia’s Modern Slavery Act (2018), and the United Kingdom’s Modern Slavery Act (2015). This Statement outlines the steps Credera has taken to identify and develop a strategy designed to better manage our exposure and ensure continuous improvement of the risks of modern slavery to its supply chain and business operations.
Credera is a consulting firm focused on strategy, transformation, cloud, data, and engineering. Our more than seven hundred consultants across the globe partner with clients ranging from FTSE 100 companies to large government departments.
Credera’s European arm (Credera Limited), previously known as DMW Group, was founded over 30 years ago and believes the most effective solutions are created through genuine collaboration with a sharp focus on pragmatism. We care deeply about building trusted relationships with our clients to deliver tangible business results.
We strive to work to the highest professional standards and comply with all laws, regulations, and rules relevant to our business.
This statement is made on behalf of Credera Limited, and each of its subsidiaries listed at the end of this statement, (together “we,” “our,” “us”).
We foster a culture of collaboration and focus on investing in our people, protecting the environment and giving back to the communities in which we operate. We have a zero-tolerance approach to any form of modern slavery and are committed to establishing effective systems and controls to safeguard against any form of modern slavery or human trafficking in our supply chain.
Operations, Structure & Supply Chains
Credera’s Business and Modern Slavery Risks
Our Supply Chain
During 2022, we undertook a review of potential risks of modern slavery practices across our operations based on guidance as provided by the UK Government and the Commonwealth Government's Department of Home Affairs.
Our key suppliers are technology service providers and software service providers. Modern forms of slavery are not typically prevalent in the industries in which these suppliers operate. We expect the same high standards as those to which we hold ourselves from those businesses with which we work. We believe the nature of our work, our supply chains, and their industries to be low risk in terms of modern slavery.
Outside of our key suppliers, we have identified potential risk areas for our business. Geographic risk may arise in situations where we have directly engaged with overseas service providers operating out of developing countries. Each year, we make significant investments in purchasing new laptops and mobile handsets with the understanding that laptops and handsets, as electronic products, have the potential to be exposed to modern slavery in their manufacturing process. Also, certain types of services that generally involve lower wages and manual labour, such as cleaning, may also give rise to modern slavery risks.
Our corporate responsibility strategy, codified in the Omnicom Group Code of Business Conduct, aims to improve the impact of our business on society and we are committed to ensuring that there is no modern slavery in any part of our supply chains or in any part of our business.
Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains. A copy of our Supplier Code of Conduct can be supplied upon request.
Our actions and findings in addressing the various risks of modern slavery practices in our business have been as follows: -
1. we have continued to update existing websites so that they contain the latest copy of our Modern Slavery Act statement and Supplier Code of Conduct.
2. we have identified that modern slavery is not prevalent in the industries of our key suppliers, and that our suppliers are not located in markets where there is a high risk and level of exposure to modern slavery.
3. we have taken a risk-based approach in carrying out our zero-tolerance stance towards modern slavery. This risk-based approach requires various procedures to be performed in identifying suppliers who may have a higher risk profile with regards to modern slavery; and
4. we have performed an annual analysis of overseas suppliers engaged throughout the year and have assessed whether any are based in high-risk countries. We have identified products that we have purchased throughout the year (e.g., laptops/handsets) that may have a higher risk of modern slavery in their manufacture.We have identified services that we have engaged in the UK and Australia that are generally low paid and involve manual labour. For these suppliers that have been identified as having a higher risk of modern slavery, we have assessed our relationship with the supplier. Where we possess significant leverage with the supplier, we have requested detailed and ongoing reporting of financial data from the supplier to ensure there is no indication of modern slavery within their work force.
How Credera Assesses and Addresses Modern Slavery Risks
Assessing Modern Slavery Risks, Ongoing Monitoring and Consultation
To assess the ongoing effectiveness of its measures to combat modern slavery, Credera takes the following steps: -
1. we audit our policies relevant to modern slavery on an annual basis to assess performance against established industry benchmarks and update them as required.
2. we conduct periodic reviews of our organisation and supply chain structures and assess whether there are any changes to the level of risk of modern slavery; and
3. we consult with Credera entities as part of its ongoing assessment and for the purposes of determining any further steps required to address the risks of modern slavery within their organisations and supply chains.
Code of Business Conduct and Ethics
Our corporate responsibility strategy, codified in the Omnicom Group Code of Business Conduct, aims to improve the impact of our business on society and we are committed to ensuring that there is no modern slavery or human trafficking in any part of our supply chains or in any part of our business.
Our Supplier Code of Conduct reflects our commitment to acting ethically and with integrity in our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our supply chains.
Ongoing Monitoring of Modern Slavery Risks
Our steps to implement this new Supplier Code of Conduct are ongoing and are as follows:
1. communicating the new Supplier Code of Conduct to our suppliers.
2. aiming for our new supplier contracts to contain express warranties and indemnities regarding compliance with the Modern Slavery Act 2015 and our new Supplier Code of Conduct; and
3. taking a zero-tolerance approach to suppliers who fail to comply with our new Supplier Code of Conduct, other relevant policies, and procedures and with applicable laws.
We continue to review our policies and processes to go beyond basic social and environmental regulations and to ensure the highest standards in our supply chain, as expected by our customers and the companies with which we work.
We understand that this is a continual process in our efforts to ensure that no form of forced labour or slavery is present in our business or our supply chain. We continue to work on:
1. identifying relevant members of staff who would benefit from anti-modern slavery and anti-human trafficking training and guidance, so that training and guidance may be provided; and
2. identifying the risks and level of exposure within our supply chain and managing such risks responsibly.
Where the supplier produces an annual statement on modern slavery, we have obtained a copy of their statement to assess if there is any indication of modern slavery in their supply chain. And where the supplier does not have a statement on modern slavery, we have requested that the supplier complete a modern slavery questionnaire explaining what they are doing to assess and address their risks of modern slavery.
Reporting Concerns related to Modern Slavery
Any Credera employees, associates, or contractors are encouraged to report any suspicious activity which may be considered to fall within the realm of Modern Slavery. All employees, associates, and contractors undertake Annual Mandatory Training to build and maintain awareness.
To report any concern, please contact via email to firstname.lastname@example.org
Training related to Modern Slavery
Credera staff, associates and business partners providing resources to Credera must undertake Modern Slavery Mandatory training at Induction and Annually thereafter. Training is monitored for compliance and a “Real Time” training dashboard is used to validate/evidence compliance and is used as a “Key Performance Indicator.”