Modern Slavery Act
This statement outlines V4 UK Holdings Limited’s commitment to addressing and mitigating the risks of modern slavery and human trafficking across its business operations and supply chains. It details the steps and measures we have taken, and will continue to take, to ensure compliance with the Modern Slavery Act 2015, Section 54(1), and to uphold high ethical standards within our organisation and its supply chain.
Our Structure and Business
V4 UK Holdings Limited, the parent company of Bloom Procurement Services Limited and V4 Services Limited, operates in the UK public procurement sector, with 98 UK-based employees. V4 Services delivers business consultancy across sectors, including leisure, health and social care, and procurement. Bloom provides a managed procurement service, facilitating a compliant, outcome-based supply chain for public sector clients to access professional and consultancy services through a diverse range of suppliers.
Our Approach and Commitment to Combatting Modern Slavery
We are committed to preventing any form of modern slavery or human trafficking within our business and supply chains. This commitment is reflected in our organisational values and operational practices. We expect the same standards from our suppliers and maintain a zero-tolerance policy toward any violation. This is underpinned by the following guiding principles:
- Curiosity and Improvement: We continuously evaluate our practices and seek improvements to strengthen our anti-slavery measures.
- Collaboration and Accountability: We foster an environment of accountability, working closely with suppliers and partners to uphold these standards.
- Integrity and Respect: We uphold respect in all interactions, ensuring a transparent and ethical business culture.
Assessing and Managing Modern Slavery Risks
Through our supplier accreditation process, all suppliers undergo checks, including self-certification and documentation review. This process helps us understand potential risks and ensure compliance with our anti-slavery standards. We have also collaborated with an academic partner to benchmark our processes against best practices within the UK professional services sector, aiming to enhance our supply chain due diligence.
Our Due Diligence and Supplier Code of Conduct
In line with our zero-tolerance policy, we have established clear procedures to assess, monitor, and mitigate risks related to modern slavery. Our Supplier Code of Conduct, introduced last year, specifies expectations around:
- Prohibition of forced or involuntary labour
- Maintaining safe and healthy working conditions
- Ensuring no child labour or exploitation
- Paying the Real Living Wage
- Prohibiting excessive working hours
- Zero tolerance for discrimination
- No harsh or inhumane treatment
We have integrated these standards into our contracts and maintain the right to terminate any contract in the event of non-compliance with the Modern Slavery Act or our ethical standards.
Policies Supporting our Anti-Slavery Commitment
Our policies underscore our commitment to ethical practices and are integral to combatting modern slavery:
- Corporate Responsibility Policy: We aim to act responsibly within the wider community.
- Equality and Diversity Policy: We are dedicated to promoting equality to reduce vulnerabilities that can lead to exploitation.
- Recruitment and Selection Policy: We enforce strict right-to-work checks, preventing forced or involuntary employment.
- Whistleblowing Policy: Employees can report any concerns confidentially and without fear of reprisal.
- Health and Safety Policy: We provide a safe work environment, prioritising the welfare of all employees and contractors.
Risk and Compliance Assessment
We conduct regular evaluations of our exposure to modern slavery risks, which remain low due to our operations solely within the UK, serving accredited suppliers in professional services. However, we remain vigilant and continuously seek assurances from our suppliers to uphold our anti-slavery standards. Our ongoing risk assessment includes engagement with clients and suppliers throughout the procurement cycle to reinforce these standards.
Measuring Our Effectiveness
To ensure continuous improvement and accountability, we have set the following Key Performance Indicators (KPIs) for 2024 and 2025:
- KPI 1: All employees to complete eLearning on modern slavery by 31 December 2024.
- KPI 2: New employees to complete modern slavery eLearning within six weeks of induction.
- KPI 3: Annual review of our Risk Ledger to be completed by 31 December 2025.
- KPI 4: Review and update all key policies (Corporate Responsibility, Equality and Diversity, Recruitment and Selection, Whistleblowing, Health and Safety) by 31 December 2025.
Training and Capacity Building
We regularly update our training programs to equip employees with the knowledge to identify and respond to modern slavery risks. Training completion is monitored to ensure comprehensive coverage across the organisation.
Future Actions and Next Steps
We are dedicated to improving our understanding of supply chain risks and to maintaining transparency in our anti-slavery measures. In the coming year, we will:
- Update and publicly disclose our response in the GOV.UK Modern Slavery Assessment Tool (MSAT).
- Renew our due diligence procedures to address risks of slavery, human trafficking, money laundering, and exploitation.
- Track and increase the number of suppliers committed to our Supplier Code of Conduct. Identifying and prioritising those suppliers that provide professional services at the lower end of the pay scales e.g. facilities management sector.
- Support initiatives to engage with SMEs, fostering local economic growth and reducing vulnerabilities to modern slavery within our communities.
This statement, approved by the Board on 25th November 2024, reflects our commitment under Section 54(1) of the Modern Slavery Act 2015 for the financial year commencing 1 January 2024.
Adam Jacobs - Director
V4 UK Holdings Limited
Date: 8/1/2025