THEO TOPCO LIMITED MODERN SLAVERY STATEMENT FOR THE FINANCIAL YEAR ENDED 31ST DECEMBER 2024
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Theo Topco Limited and its subsidiaries (“Key Group”) slavery and human trafficking statement for the financial year ending 31 December 2024.
Whilst we consider the risk of the existence of slavery and human trafficking within our business or supply chains to be very low, we are committed to combatting modern slavery in all its forms. We take a zero-tolerance approach to modern slavery.
Key Group has policies and processes in place to mitigate the risk of slavery and human trafficking issues arising within its business and supply chains, including:
Our Sustainability report reflects Key Group’s commitment to acting ethically and with integrity in all our business relationships.
Our Third Party Management Framework reflects our approach to both onboarding and ongoing management of our Third Party Suppliers
Our Grievance Policy, Anti-Harassment & Bullying Policy and our Whistleblowing Policy which is aimed at giving our colleagues a platform to raise concerns of any wrongdoing or poor working practices. This extends to human rights violations, including modern slavery. All such reports will be fully investigated and appropriate remedial action taken.
Our recruitment policies involve conducting appropriate checks on all new joiners, and mandates that no individuals are paid below the minimum wage, either within the Group itself or across our suppliers. Internally we have opted to pay above the National Living Wage, including for example for our cleaning services contract.
We conduct appropriate initial and ongoing due diligence checks over our Suppliers and this approach is outlined further in section 4.
We source goods and services from a variety of suppliers including:
IT – software and hardware
Telephony
Office accommodation and supplies
Professional services such as marketing, legal etc.
External funding partners
Cleaning
As part of our risk management approach we conduct due diligence on potential suppliers, impose obligations on those suppliers in relation to (among other things) compliance with law, and take reasonable steps to monitor their compliance with those obligations. This approach is outlined in our Third Party Management Framework which is reviewed and approved at least annually.
We conduct all business with integrity and are committed to acting professionally and fairly in all our business dealings and relationships.
Our procurement activities take place in the UK and our contractors and suppliers are predominantly UK based, although a minority are based in the EU. Some of our suppliers subcontract work or rely on recruitment agencies to supply permanent or temporary staff. Whilst we consider that the risk is very low, we recognise that no supply chain can be considered entirely risk free.