Modern Slavery Policy

Modern Slavery Statement and Policy

About Weee Recycle ICT 

Weee Recycle ICT, located in Kent, offers IT products and services throughout the United Kingdom and Europe.

Weee Recycle ICT is dedicated to making a meaningful and enduring impact on the IT sales process by providing a comprehensive circular procurement cycle for clients, benefiting both the environment and future generations.

We empower our clients to enhance education, health, and overall quality of life for individuals in the UK, or to transform their businesses for increased productivity and value. Our journey commenced in 2007, and since that time, we have supported hundreds of organizations in adapting to and thriving within the ever-evolving technology landscape by implementing valuable technology, offering tailored recycling services, and delivering dependable support.

Weee Recycle ICT is a technology reseller in the UK with an onsite recycling facility, bolstered by the data protection certifications we have obtained. As a technology provider, our clients expect us to advocate for a more sustainable future. From educational institutions to hospitals, governmental bodies to small startups, and large corporations – Weee Recycle ICT creates data asset solutions tailored to our clients’ requirements, with full assurance that we can assist them in reaching their recycling and reuse objectives.

An essential aspect of responsibly delivering products and services to our clients, attracting and retaining exceptional talent, achieving sustainable growth, and providing innovative solutions that offer value for money, is our Modern Slavery Statement and Policy.

This document outlines how we recognize and address risks as a business, the processes we implement, and the policies our employees and suppliers are required to adhere to and support in order to comply with the Modern Slavery Act 2015, our core values, and our Code of Business Conduct. It applies to all products and services offered by Weee Recycle ICT, as well as to all employees, contracted resources, and suppliers (without exception).

At Weee Recycle ICT we will not tolerate any form of human rights abuse, including modern slavery or human trafficking, in any part of our business or within our supply chain.

About our supply chains

Weee Recycle ICT boasts a comprehensive array of suppliers, subcontractors, and partners included on our approved supplier roster. Prospective suppliers seeking to provide goods or services to our clients must adhere to our Modern Slavery standards and codes of conduct that align with industry norms, particularly as outlined by the Chartered Institute of Procurement and Supply (CIPS).

All suppliers and subcontractors must follow our essential onboarding protocol. During the onboarding process (and again when suppliers are revalidated), we ask suppliers to fill out an extensive questionnaire. This questionnaire comprises:

• Confirmation and commitment to comply with our Modern Slavery Statement and Policy, along with other associated policies, such as our Health and Safety Policy Statement and Supplier Code of Conduct.
• Completion of our Modern Slavery Questionnaire, which includes a request for access from external auditors (if necessary).

All (100%) employment agencies that Weee Recycle ICT may engage for labor services will be evaluated regarding their Modern Slavery processes and procedures before being utilized.

Policies in relation to modern slavery and human trafficking, and our governance structure

The Board of Directors, facilitated by Weee Recycle ICT’s Compliance Coordinator implements, and oversees our company-wide human rights commitments (found within the policies and procedures below) and the design of processes to prevent, mitigate, and remediate related impacts, including any relating to modern slavery:

• Modern Slavery Statement and Policy
• Environmental Policy
• Information Security Policy
• Health and Safety Policy
• Grievance Policy and Procedures
• Disciplinary Policy and Procedures
• Equality, Diversity, and Inclusion Policy and Procedures
• Sustainability Policy
• Code of Business Conduct
• Concerns About the Behaviour of Others (“Whistleblowing”). Whistleblowing Policy and Procedures

This combined annual statement and policy is led, prepared, and is ultimately owned by the Company Director. However, in recognition that all business functions across the company play a role in addressing modern slavery risks, the following functions were specifically consulted in the preparation of this joint statement and policy:

• Human Resources
• Warehouse & Logistics
• Technical Services
• IT Asset Disposal Services and Operations
• Commercial and Sales
• Marketing
• Research and Development
• Bids and Tenders
• Sustainability
• Risk and Compliance

Due diligence

Integrity in our practices

Upholding human rights is fundamental to our core principles, which emphasize “we believe in people.” This means treating one another, our clients, and our partners with dignity. We prioritize “integrity” in all our actions. Together, we uphold ethical standards; our instinct is to always make the right choices, taking both personal and collective accountability. As employees of Weee Recycle ICT, we recognize our responsibility for our actions.

This sense of responsibility, respect, and accountability is ingrained in our core values and is reflected throughout our value chain and the communities in which we operate. A dedication to these principles is essential for every Weee Recycle ICT employee, as they ensure compliance and integrity in our conduct across all operations. We are committed, both as an organization and as individuals, to adhering to all relevant laws and regulations wherever we deliver goods and services.

Identifying areas of risk

As a provider of IT manufacturing and IT Asset Disposal services, Weee Recycle ICT possesses a strong understanding of any possible risks within its supply chain and operations. We maintain solid, long-term partnerships with our suppliers (Tier One Partners and component suppliers for our proprietary hardware), all of whom have established policies, governance structures, and dedicated teams responsible for overseeing their own supply chain and operational risks.

Suppliers Code of Conduct and audits

We conduct regular evaluations of risks to pinpoint significant threats of modern slavery and human trafficking within our operations and supply chain. As a company, we are always seeking methods to reduce the likelihood of modern slavery incidents occurring in our supply chain.

During the onboarding and revalidation process, as well as upon review and completion of the Modern Slavery Questionnaire, suppliers are requested to affirm their consent to an audit of their procedures and policies. Additionally, each supplier must confirm their acceptance of appointing an external auditor, if Weee Recycle ICT decides to pursue this option. If there is any pushback against this requirement, it is considered a 'red flag'. We engage with the supplier (for instance, they might initially resist due to worries about potential operational disruptions) and reach an agreement for the audit to take place within a timeframe that is acceptable to both parties. Should the supplier persist in declining the audit, Weee Recycle ICT may then seek independent advice.

The responsibilities outlined in our code of conduct are reinforced by our standard supplier terms, which grant us the right to terminate agreements immediately via written notice under certain conditions, including any violation of applicable laws (such as the Modern Slavery Act) or a significant breach of the Code of Conduct.

Fair pay for Staff

We are committed to ensuring that all our people are paid fairly and we ensure we meet the UK national living minimum wage standards.  We do not have zero hour contracts.

Recruitment

Our hiring team collaborates closely with our compliance and risk management department to guarantee that our hiring and vetting procedures are suitable for their intended purpose and that any cases of modern slavery are detected, reported, and addressed promptly.

Weee Recycle ICT’s hiring team has completed training on Modern Slavery, which covers recognizing indicators that may suggest someone is a victim of Modern Slavery. Relevant checks are also performed as part of the onboarding process, which itself is regularly subject to external auditing.

Reporting

Our Whistleblowing Policy contains guidance on how to raise any concerns that our people may have in our business or supply chain, including modern slavery. They can raise any breaches with an appropriate manager, executive team member, company auditors or the Converge anonymous online form. Alternatively they can contact the charity “Protect” on https://protect-advice.org.uk/ or by telephone 020 3117 2520. The Whistleblowing Policy contains a process, including timescales, for initial acknowledgment (3 days) and subsequent investigation of any reported concerns (14 days). If evidence were to be discovered of criminal activity the police would be informed.

We have published our 2023 Modern Slavery statement on the UK Government’s Modern Slavery Act statement registry. https://supplierregistration.cabinetoffice.gov.uk/msat

During 2023 no complaints or concerns were raised about modern slavery or human trafficking taking place to Weee Recycle ICT Limited.

Communication

Weee Recycle ICT is an innovative and dynamic organization, driven by purpose and integrity, actively identifying risks related to modern slavery across all its operations. The company's environment fosters transparency and trust, enabling all staff members to evolve and progress within the business, while bringing in external expertise as necessary. There is a focus on a growth mindset and open lines of communication.

This approach facilitates early risk detection through:

• A structured communication system, which includes team meetings, briefings, noticeboards, and an engaging intranet featuring contemporary workplace tools.
• A confidential whistleblowing mechanism, ensuring employees feel secure knowing they are protected by law when making confidential reports.
• A thorough collection of mandatory onboarding training sessions that must be completed within the first two weeks of employment, followed by refresher courses. These sessions are designed to inform all employees about risk identification and management concerning issues like Modern Slavery, Safeguarding, and Equality, Diversity, and Inclusion.