Ethical Trading and Modern Slavery Statement

Introduction

CYAN is committed to upholding the highest standards of ethical trading and preventing modern slavery across all aspects of our business and supply chain. This policy outlines our approach to identifying, managing, and mitigating risks related to unethical labour practices, ensuring compliance with all relevant legal, regulatory, and contractual requirements. By embedding responsible sourcing and fair labour practices into our internal processes and supplier relationships, we aim to build a transparent and accountable framework that supports our commitment to human rights and fosters trust with our customers, partners, and communities.

Purpose

The purpose of this Ethical Trading and Modern Slavery Policy is to ensure that CYAN conducts its business in a socially responsible and ethical manner, respecting human rights throughout our operations and supply chain. This policy establishes the principles, standards, and procedures CYAN must follow to prevent modern slavery, human trafficking, and other unethical labour practices.

This policy applies to:

Internal Operations: Ensuring that all internal processes, procurement activities, and supplier relationships comply with the highest standards of ethical trading and human rights due diligence.

By adhering to this policy, CYAN aims to:

Prevent modern slavery and human trafficking within our business and supply chain.
Promote fair and safe working conditions for all workers involved in our operations and those of our suppliers.
Ensure compliance with relevant legal, regulatory, and contractual requirements related to ethical trading.
Support CYAN’s commitment to corporate social responsibility by embedding ethical considerations into all aspects of our business.

Scope

Applicability

This policy applies to all CYAN employees, contractors, temporary staff, agency workers, and any other individuals engaged in work for or on behalf of CYAN.

It covers all aspects of ethical trading and modern slavery prevention within CYAN’s operations and supply chain, including procurement, sourcing, and supplier management.

While this policy does not directly govern third-party organisations beyond CYAN’s control, CYAN requires due diligence and contractual commitments from all suppliers and service providers to ensure they comply with ethical trading standards and anti-slavery legislation.

This policy is designed to ensure that CYAN’s internal operations and external partnerships uphold the highest standards of ethical conduct, human rights, and corporate social responsibility.

Policy

Overview

CYAN Solutions recognises that our commercial activities can have a significant impact on our suppliers, local communities, and customers. As a socially responsible organisation, we believe these stakeholders have the right to expect that:

All workers involved in delivering services for CYAN Solutions are treated with full respect for their fundamental human rights.
CYAN Solutions conducts its business ethically, exceeding the minimum requirements of the law.
We are committed to upholding the principles of the Ethical Trading Initiative Base Code, even though we are not formal members of the ETI.

This policy outlines CYAN Solutions’ commitment to ethical trading and modern slavery prevention, detailing the actions we are taking to ensure responsible and fair practices throughout our supply chain and operations.

Code of Practice

This Code of Practice Applies To:

Staff directly employed by CYAN Solutions on temporary or permanent contracts. 
Staff employed or provided by contractors or employment agencies to work on CYAN Solutions’ premises or to undertake work for or on behalf of CYAN Solutions

Employment Is Freely Chosen

No forced, bonded or involuntary labour shall be used. 
Staff are not required to lodge deposits or identity papers with us. 
Staff are free to leave CYAN Solutions after reasonable notice.

Working Conditions Are Safe and Hygienic

Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment. 
Staff receive health & safety information. 
Staff have access to toilet facilities and drinking water. 
CYAN Solutions has a published Health & Safety Policy.

Child Labour Shall Not Be Used

There shall be no recruitment of child labour. 
Children or persons under 18 are not employed at any time, day or night.

Living Wages Are Paid

Staff pay rates are equal to or above the national legal minimum standards. 
Staff are given information about their employment conditions in respect to wages 
No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful  deductions are provided for each pay period. 
Staff are given clearly understandable written terms and conditions of employment that details the employment relationship and the respective obligations of the employee and employer.

Working Hours Are Not Excessive

Staff are not forced to work in excess of 48 hours per week, a voluntary opt out agreement is available for those wishing to work in excess of 48 hours per week.

No Discriminations Is Practiced

There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age, disability, marital status, sexual orientation, union membership or political affiliation. 
Opportunities for personal and career development are equally available to all employees.

No Harsh or Inhumane Treatment Is Allowed

Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal, if proved.

Responsibilities

The ISO Committee has collective responsibility for the effective operation of this policy. They are responsible for monitoring and reviewing the policy, making recommendations for changes to reduce the risk of unethical labour practices and ensure compliance with modern slavery legislation and ethical trading standards.

Internal Responsibilities

ISO Committee: Oversees the implementation and effectiveness of the Ethical Trading and Modern Slavery Policy procedures. They monitor compliance, review the policy regularly, and propose necessary changes to enhance the protection of human rights, ethical business conduct, and supply chain transparency.
All Staff: Accountable for their own compliance with this policy and ensuring it is consistently applied. All staff should read and understand the policy. Any breaches of this policy should be reported to a member of the ISO Committee
Head of People: Primary point of contact for questions regarding the content or application of this policy. In their absence, the Head of Finance assumes these responsibilities.

By defining these responsibilities, CYAN ensures that our internal operations are managed in alignment with the highest standards of ethical governance and social responsibility. This collaborative approach helps maintain the integrity of our supply chain, uphold human rights, and ensure ongoing compliance with modern slavery legislation.

CYAN owns all its Policies and Procedures. To protect the integrity and accuracy of our documentation, the following rules apply:

Authorisation Requirement: Staff must not share CYAN’s policies and procedures with other organisations unless authorised by the Head of People or, in their absence, the Head of Finance.
Purpose: This requirement ensures that only the most current and accurate information is shared, protecting individuals and CYAN from the risks associated with outdated or incorrect information.

By maintaining strict control over the sharing of policies and procedures, CYAN ensures that both internal and external stakeholders receive accurate and reliable information, thereby maintaining high standards of transparency, ethical compliance, and accountability and operational excellence.

Review and Continuous Improvement

Regular Reviews and Audits

CYAN will conduct regular reviews and audits of our policies and processes to ensure they remain effective and compliant with current standards.

Findings from reviews and audits will be used to continuously improve our policies and procedures.

Continuous Improvement

Continuous improvement processes will be in place to update and enhance policies in response to new threats and changes in the regulatory landscape.

Improvements will be documented and communicated to all relevant stakeholders to ensure awareness and implementation.

Policy Compliance

Internal Compliance

It is a condition of employment that all CYAN employees, contractors, temporary staff, and other workers abide by the rules and policies set forth by CYAN. Any failure to follow this policy may result in disciplinary action in accordance with CYAN’s disciplinary procedures.

Understanding and Adherence: Employees must ensure they understand the implications of this policy and how it applies to their role. If any part of this policy is unclear, employees should seek advice from their Line Manager or the Head of People.
Reporting Violations: Any suspected or actual breaches of this policy must be reported immediately to a member of the ISO Committee.

Enforcement

CYAN reserves the right to take appropriate action against any individual or entity that fails to comply with this policy. For employees, this may include disciplinary measures up to and including termination of employment.