Modern Slavery Statement

The Modern Slavery Act 2015

This is the statement by Ignite Software Systems Ltd (“Ignite”, “we”, “our”) which sets out the organisation’s commitment to tackling slavery and human trafficking in our supply chain and in our business.

Organisation’s Structure

Ignite is a provider of software services in the financial services sector in the United Kingdom.  Our parent company is Goorlie Holdings Limited, which has its head office in Guernsey.

Our supply chain primarily consists of goods and services purchased to assist in the delivery of our software services to our customers.

Ignite’s Supply Chains

We are committed to ensuring that there is no slavery or human trafficking in any part of our supply chains or in any part of our business. We have taken a number of steps to assess, address and mitigate the risk of slavery and human trafficking in our supply chain in the previous financial year:

1. Policies

We reviewed our policy library to ensure the issue of slavery and human trafficking is sufficiently addressed, and made some key changes to those policies. A number of Ignite’s policies address the issue of slavery and human trafficking in our supply chains:

a) Ignite’s Procurement Policy, details the principles and standards the business must adhere to when searching, evaluating, selecting, contracting and managing external suppliers. The Procurement Policy explicitly references adherence to the Modern Slavery Act 2015;

b) Ignite’s Outsourcing Policy, details the principles and standards the business must adhere to when outsourcing services (which means the transfer of existing business processes to a third party, or a function which is critical to performance of Ignite’s business). Ignite’s Outsourcing Policy explicitly references adherence to the Modern Slavery Act 2015.

2. Suppliers

As part of Ignite’s initiative to identify, address and mitigate risk in relation to slavery and human trafficking in reference to new suppliers, Ignite:

a) has incorporated clauses into all standard contracts with new suppliers to ensure suppliers contractually commit to comply with the Modern Slavery Act 2015. It is one of Ignite’s fundamental contracting principles that there is an obligation to comply with the Modern Slavery Act 2015 in all contracts with new suppliers;

b) has incorporated audit clauses into all standard contracts with new suppliers to allow Ignite the ability to audit those suppliers to ensure compliance with its obligations under the contract, including in relation to compliance with the Modern Slavery Act 2015. It is one of Ignite’s fundamental contracting principles that in all contracts with new suppliers Ignite has the right to audit that supplier.

Ignite’s Business

We have also taken a number of steps to assess, address and mitigate the risk of slavery and human trafficking within our own business in the previous year:

Policies

A number of Ignite’s policies address the issue of slavery and human trafficking in the context of our business:

a) Ignite’s Human Resources Policy, which details Ignite’s approach to the recruitment, retention, management, performance, development and health and safety of all Ignite colleagues, including the principle that all colleagues conduct themselves in an appropriate manner inside and outside of work;

b) Ignite’s Recruitment and Selection Policy, which details Ignite’s commitment to maintain the highest standards of integrity and honesty in our selection process;

c) Ignite’s Pay and Reward Policy, which details Ignite’s commitment to have a legally compliant and transparent pay and reward scheme for employees.

In The Next Financial Year

In this financial year, we aim to:

• Further review our policy library to ensure the issues of slavery and human trafficking are properly addressed, and make changes as necessary;
• Carry out an assessment of our current supply chain, assessing the supply chain in the context of key high-risk indicators including geographical location of the supplier and supplier sector, to ensure existing suppliers at risk of slavery and human trafficking practices, are identified. We are then asking those suppliers to declare they are compliant with Modern Slavery Act 2015;
• Further develop our due diligence processes in our procurement process. We have already developed a definition of ‘high risk’ suppliers in the context of the Modern Slavery Act 2015 to consider whether a supplier is high risk in the context of modern slavery. In addition, we are also in the process of developing a declaration for new suppliers engaged by Ignite with the purpose of assessing the risk of that supplier in the context of the Modern Slavery Act 2015, and are in the process of embedding it as part of Ignite’s overall procurement process;
• Provide further training on slavery and human trafficking to employees, as appropriate.

This statement is made by Ignite Software Systems Limited on behalf of itself pursuant to section 54(1) of the Modern Slavery Act 2015.

Toby MacLachlan
MD, Ignite Software Systems Limited