Modern Slavery Statement

Scope of this statement

Section 54 of the Modern Slavery Act 2015 requires a slavery and human trafficking statement from commercial organisations with a total annual turnover of £36 million or more. ActiveManage Ltd is below that threshold, so this statement is voluntary and is not made under section 54.

We publish it because our customers include NHS trusts and other public bodies whose own procurement rules require them to understand their supply chain, and because the exercise of writing it is worth doing regardless of whether a statute compels it.

This statement covers the financial year ending TODO_FINANCIAL_YEAR_END and applies to the whole of ActiveManage Ltd. We have no subsidiaries.

Our business

ActiveManage Ltd (company number 10448163) is a software company registered in England and Wales, with its registered office at ActiveManage Ltd., Enterprise Centre, David Lane, Basford, Nottingham, NG6 0JU. We build and operate the ActiveManage low-code development platform, and we deliver bespoke business applications on it.

We employ TODO_HEADCOUNT people, all of them in the UK. All staff are directly employed on contracts that meet or exceed statutory minimums, paid at or above the National Living Wage, and hold the right to work in the UK, verified before employment begins. We do not use employment agencies for temporary or seasonal labour, and we do not operate in any sector conventionally associated with a high risk of forced labour.

Our supply chain

Our supply chain is short, and almost all of our spend falls into five categories:

We do not manufacture anything, hold physical stock, or operate a logistics or distribution network. We do not employ or contract labour outside the UK. TODO_MS_OFFSHORE_SUBCONTRACTING: state here whether any development, testing, support or data-processing work is subcontracted offshore, and to whom — if it is, that is the most significant item on this page and it belongs above the table, not in a footnote.

Where the risk actually is

It would be easy, and not very useful, to conclude that a UK software company has no modern slavery risk. Two areas are worth naming honestly:

• Facilities services. We occupy serviced office space, which means the cleaning, security, catering and maintenance contracts are let by our landlord rather than by us. These are labour sectors with a documented history of exploitation, and they are the part of our supply chain where we have real exposure and the least direct control.
• Hardware manufacture and mineral extraction. Every laptop we buy has a supply chain reaching into electronics assembly and, beyond that, mineral extraction. Our purchasing volume gives us no leverage over it, but pretending the risk is not there because we cannot influence it would be dishonest.

Beyond that, the standard indicators of forced labour — recruitment fees, withheld documents, tied accommodation, unexplained deductions, third-party control of wages — do not arise in a directly employed UK professional workforce, which is what we are.

The steps we take

• Right-to-work checks on every employee before employment starts, with records retained.
• Direct employment. We do not engage labour through agencies, umbrella companies or intermediaries where visibility of terms and pay would be reduced.
• Supplier screening at onboarding. For any new supplier above TODO_SUPPLIER_THRESHOLD annual spend we check for a published modern slavery statement or, where the supplier is below the threshold as we are, an equivalent commitment.
• Contractual terms. Our standard supplier terms require compliance with the Modern Slavery Act 2015 and the right to terminate for a breach.
• Preference for UK and EU suppliers where a comparable service exists, which shortens the chain and puts more of it inside a regulated labour market.
• A reporting route. Any employee, contractor or supplier can raise a concern to TODO_RESPONSIBLE_DIRECTOR at info@activemanage.co.uk. Concerns can be raised anonymously and are covered by our whistleblowing procedure, which protects the person raising them.
• We raise facilities services with our landlord as part of the annual review of this statement, and ask what assurance they hold over the contracts they let on our behalf.

Training and awareness

Everyone involved in purchasing or in engaging people is briefed on the indicators of forced labour and on how to raise a concern. Given our size this is a briefing and a written procedure rather than a formal training programme, and we would rather describe it accurately than call it something grander.

TODO_MS_TRAINING_CONFIRM — confirm the paragraph above matches what actually happens, and record the date it was last delivered.

Measuring effectiveness

We track three things, and report them in this statement each year:

• The proportion of supplier spend covered by a modern slavery statement or equivalent commitment. Current figure: TODO_MS_SPEND_COVERED_PCT.
• The number of concerns raised through any route, and their outcome. In the year covered by this statement: TODO_MS_CONCERNS_RAISED.
• Whether every new supplier onboarded in the year was screened. In the year covered by this statement: TODO_MS_ALL_SUPPLIERS_SCREENED.

These are deliberately small, countable measures. A company of our size that claimed a comprehensive audit programme would not be believed, and should not be.

Approval

This statement was approved by the board of ActiveManage Ltd on TODO_MS_BOARD_APPROVAL_DATE and is reviewed annually.

Signed: TODO_DIRECTOR_NAME, TODO_DIRECTOR_TITLE, for and on behalf of ActiveManage Ltd.

A signed PDF of this statement, on letterhead, is available from info@activemanage.co.uk for procurement portals that require an uploaded document rather than a URL.