Modern Slavery Statement
Purpose
Climb Global Solutions EMEA Ireland Limited (“the Company”) operates a zero tolerance to slavery and human trafficking.
This statement is made in relation to the Modern Slavery Act 2015 and constitutes the Company’s slavery and human trafficking statement for the current year.
Climb Global Solutions EMEA Ireland Limited expects all those in our supply chain to comply with our values and to have suitable anti-slavery and human trafficking policies and processes.
This statement reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
Scope
This statement applies to Climb Global Solutions EMEA Ireland Limited its employees and managers and extends to any organisation or individual that Climb Global Solutions EMEA Ireland Limited conducts business with.
Organisational structure and supply chains
This statement covers the business activities of Climb Global Solutions EMEA Ireland Limited which are as follows: The Company consists of three areas of business. Selling developer and technical software to businesses, distribution of software to resellers and also deliver professional services and support.
The Company operates in Ireland but sells worldwide, except to IT embargo countries.
The Company has reviewed all associated partners and considers our business dealings to be low risk.
Responsibility for the Company’s anti-slavery initiatives is as follows:
1.1 Policies: Director of Team Engagement & Experience is responsible for creating and reviewing policies. The process by which policies are developed is to look at best practices, taking external advice and creating a policy which is reviewed and agreed by Senior Leaders.
1.2 Risk assessments: The Office Manager and Director of Team Engagement & Experience are responsible for risk assessments in respect of human rights by a process of reviewing individuals and completing Risk Assessment documentation.
1.3 Due diligence: The Vendor Manager is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.
1.4 The Senior Leadership Team are accountable for making sure the company is acting with due diligence and will ensure any risk assessments are carried out prior to engaging with suppliers and customers.
1.5 The Senior Leadership Team are responsible for supply chain verification for existing and future suppliers in relation to the Modern Slavery Act.
1.6 All Team Leaders, Heads of Department, Senior Managers and the Senior Leadership Team will have training on modern slavery and the implications for the Company.
Training
To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to complete Modern Slavery and Human Trafficking training on their first day of joining the during Induction. Thereafter all Staff will receive mandatory annual Modern Slavery and Human Trafficking training.
Policies
The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.
The following policies set down our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations.
2.1 Protected Disclosure Whistle Blowing Policy – the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
2.2 The Company Code of Ethics and Business Conduct – The Code of Conduct sets down the actions and behaviour expected of employees when representing the Company.
2.3 Corporate Social Responsibility (CSR) Statement – The Company’s CSR policy summarises how we manage our environmental impacts and how we work responsibly with suppliers and local communities.
Due Diligence Processes for Slavery and Human Trafficking
The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes Contract Compliance, building long-standing relationships with suppliers and making clear our expectations of business partners and evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.
Performance indicators
The Company uses the following key performance indicators (KPIs) to measure how effective we are in ensuring slavery and human trafficking is not taking place in any part of our business or supply chains including requiring all [relevant] staff to have completed training on modern slavery as soon as they start with the Company.
This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated, as necessary. Matthew Whitton, Jane Silk, Gerard Brophy and Caroline Knott endorse this policy statement and are fully committed to its implementation.
This Modern Slavery and Human Trafficking Statement has been approved and authorised by:
Valid for: 01.05.2023 – 31.04.2024
Review and consultation process: Annually from approval date above. The Senior Leadership Team to review and ensure that findings of any risk assessments are taken into consideration and that the policy remains relevant.
Responsibility for Implementation & Training: Director of Team Engagement & Experience
Distribution: Intranet for internal communications, web site and emailed link for affected business partners.