A) ORGANISATION

This statement applies to Gazelle Global Consulting Ltd (referred to in this statement as ‘the Organisation’).

B) ORGANISATIONAL STRUCTURE

The organisation is headquartered in Chiswick Business Park in London. In addition, we have smaller offices in Germany, Netherlands and France all operating as separate legal entities. The organisation is managed by a Board of Directors.

Our main business activity is recruitment of independent contractors within the IT industry in Europe.

The labour supplied to the Organisation in pursuance of its operation is carried out by independent self-employed contractors (for our end clients) and by our own employees at our offices.

C) DEFINITIONS

The Organisation considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement.

D) COMMITMENT

The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other Organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in The United Kingdom and the Netherlands, and in most cases more than exceeds these.

E) SUPPLY CHAINS

In order to fulfil its activities, the organisation’s main supply chain include those related to IT contractors. The contractors are all working through their own companies or through independent umbrella companies not affiliated with Gazelle.

F) POTENTIAL EXPOSURE

The Organisation considers its main exposure to the risk of slavery and human trafficking to exist with third-party contractors that use subcontractors.

In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any Organisation that supplies goods and/or services to it.

G) STEPS

The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its Organisation or supply chains, including conducting a review of the controls of its suppliers.

The Organisation has not, to its knowledge, conducted any business with another Organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following step to ensure that modern slavery is not taking place:

• Assess risk associated with all suppliers and include termination powers in contracts with suppliers that we deem higher risk; in the event they are, or suspected to be, involved in modern slavery. To this day we have not identified any of our suppliers to be in this category.

H) KEY PERFORMANCE INDICATORS

The Organisation has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Organisation or its supply chains.

• Track number of claims, or suspicions, of modern slavery the organisation receives and investigate these as a priority.

I) POLICIES

The Organisation shares this statement internally and makes it available to employees.

J) TRAINING

The Organisation is in process of rolling out a centralised training website for all our employees where we aim to include training on modern slavery as one of the requirements.

K) SLAVERY COMPLIANCE OFFICER

The Organisation has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.