Ethical Supply Chain and Modern Slavery Policy
How we choose and check the suppliers and delivery partners we work with, and our position on modern slavery.
Our position
ASTRI DEVS LTD does not tolerate slavery, servitude, forced or compulsory labour, human trafficking or child labour, in our own operations or in our supply chain. We expect the same of everyone we engage.
Legal status of this document
This is a policy, not a statement under section 54 of the Modern Slavery Act 2015. That section applies to commercial organisations with an annual turnover of £36 million or more. ASTRI DEVS LTD is well below that threshold and is not required to produce a section 54 statement, so we have not labelled this document as one. Doing so would misrepresent our legal position and would tell an evaluator nothing they could rely on.
What we publish instead is what we actually do. It is proportionate to a company of our size, and we would rather it be accurate than impressive.
Our supply chain and where the risk sits
Our supply chain is short. It consists principally of:
- cloud hosting, infrastructure and software-as-a-service providers;
- specialist technical subcontractors and delivery partners engaged for particular work;
- hardware and communications equipment sourced against a client requirement, where the engagement includes technology supply;
- professional services such as accountancy and insurance.
We assess the highest inherent risk as sitting in the manufacture of hardware we source on a client's behalf, since electronics manufacturing supply chains extend well beyond our direct visibility. Our software and cloud supply chain carries a lower inherent risk. We do not claim to have audited a semiconductor supply chain, because we have not, and no company of our size honestly has.
Supplier due diligence
Before engaging a supplier or subcontractor on client work, we establish, proportionate to the engagement:
- their legal identity and registration;
- relevant experience and capability for the work proposed;
- their data protection and confidentiality obligations, in writing;
- their security position where they will have access to systems or data;
- insurance appropriate to the engagement;
- the right of individuals engaged to work where that applies;
- any conflict of interest;
- sanctions screening where the engagement or counterparty makes it relevant.
Where we source hardware, we prefer established manufacturers and authorised distributors who publish their own responsible sourcing position, and we retain records of what was bought from whom.
Contract terms
Subcontracts and delivery-partner agreements require compliance with applicable modern slavery, employment and anti-bribery law, and require the counterparty to tell us if they become aware of a problem in their own supply chain. Breach is grounds for termination.
Our own engagement practices
Everyone who works for ASTRI DEVS LTD is engaged under a written agreement, is paid at or above the applicable statutory minimum, has their right to work verified where that applies, and is free to end the engagement in accordance with its terms. We do not use unpaid work, and we do not hold anyone's identity documents.
Raising a concern
Anyone who suspects modern slavery or labour exploitation connected to ASTRI DEVS LTD or its supply chain should email info@astridevs.co.uk, marked for a director. Concerns are investigated and, where there is evidence of an offence, reported to the appropriate authority. Nobody raising a genuine concern in good faith will suffer any detriment.
Review
This policy is reviewed annually, and whenever our supply chain changes materially — for example if we begin sourcing hardware at greater volume.