Slavery & Human Trafficking Statement

Montreal Associates (Systems) Limited and its subsidiaries (“MA”) recognises that all businesses have an obligation to prevent modern slavery and human trafficking and will do its utmost to prevent abuse within its business and the supply chains through which it operates.

Slavery, servitude, forced labour and human trafficking (modern slavery) are issues of increasing global concern, affecting all sectors, regions and economies. Modern slavery is fundamentally unacceptable within MA business and supply chains and is an important element in our overall approach to business and human rights.

This statement has been published in accordance with the Modern Slavery Act (2015). It sets out the steps taken by MA during the financial year ending 2020 and highlights the steps we take to ensure compliance.

1. Organisation's Structure and supply chains

MA is a privately owned recruitment company specialising in qualified, professional, and skilled recruitment in the IT and technology market, employing over 92 people across 3 offices. MA’s head office is located in London with 2 European branches in Barcelona and Frankfurt. This group statement is covering for all MA’s entities:

• Montreal Associates (Systems) Ltd
• Montreal Associates (Systems) SL
• Montreal Associates Gmbh.

Our Business

MA provide recruitment solutions to its clients across the following clusters:

Business structure

MAS is based in the UK, with a head office in London, and offices in Barcelona and Frankfurt

Our Supply Chains

As part of its activity, MA supply chains are limited to the provision of staffing and recruitment solutions. We introduce highly skilled IT professionals in the IT sector to our Clients. We use preferred supplier lists (PSL) which undergo throughout due diligence.

For the support and maintenance of our activity such as IT support, telecommunications, cleaning, etc. we use standard and reputable services companies.

2. Our Policies in relation to slavery and human trafficking

MA is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

Our business has in place the following internal policies in relation to modern slavery and human trafficking:

• Anti-slavery Policy
• Whistleblowing Policy
• Supplier Code of conduct

Our suppliers must go through the preferred supplier selection process and adhere to MA Supplier’s Code of conduct. The latter is currently being updated and the new version will be available by the end of 2021.

Supplier should meet the following requirements:

• Have in place a policy recognising, respecting and protecting the human rights of their employees, those of their suppliers and business partners and the communities affected by the suppliers’ operations.
• Employees should be free to choose to work for their employer and to leave the company upon reasonable notice.
• Any form of discrimination, victimisation or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependants, religious belief or political opinion, age, trade union activity and offending background should be prohibited.
• All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to, without any unauthorised deductions.
• The provisions of the International Labour Organisation should be respected such that any young persons under the age of 18 should not be employed to work at night or for any hazardous work and their employment should not harm the young person’s education, health or physical, mental, moral or social development. No young persons may be employed below the age of 16.
• All slavery and human trafficking laws must be complied with including, but not limited to, the UK Modern Slavery Act 2015 and all business operations should be free from slavery and human trafficking practices, whether in the UK or elsewhere, both internally and within the supply chains and any other external business relationships.

3. Due Diligence Process for Slavery and Human Trafficking

MA has a strict compliance process and checks are carried for all candidates it supplies. When onboarding new candidates, MA requires several documents which include for instance verifying the identity and the right to work of all candidates and making sure they have a bank account in their business name into which their remuneration is paid. Placements are monitored at all stages and any reluctance to provide key compliance documents is investigated and addressed.

3.1 Suppliers

A due diligence process to select suppliers has been created. To be added on the PSL, Suppliers must undertake the following:

Stage one:

• Company Questionnaire: specific for each country
• Agree to the Montreal Associates Code of Conduct

Stage Two:

• Provide five updated testimonials

Stage Three:

• Company Checks: such as: Solvency, Directors’ history, CCJs, accreditations
• Verification is undertaken that the candidate performing the services is legally employed or engaged by the entity providing the services (such as: compliance with local labour laws, immigration, minimum wage legislation…)

3.2 KYC (Know your customer)

Due diligence is undertaken every time a new client is open. MA undertakes the following:

• Certificate of incorporation requested, and companies house information verified
• Client’s code of conduct checked against MA values
• Credit checks requested if needed
• Working conditions at the client site checked against the relevant working standards

3.3 Employees

All Employees have access to “Employee rights and benefits” in the handbooks and contracts of employment.

As explained below, all employees are given training on modern slavery and trafficking and this is monitored and documented internally.

MA’s employees have access to various means to voice concerns in total confidentiality, either through local reporting mechanisms or through the whistleblowing procedure.

4. Risk assessment and management

MA uses the services of PWC as its external auditor.

A combination of the due diligence process, policies and employees means of action, help to identify, assess and monitor potential risks in our business activities and mitigate the risk of modern slavery our supply chains.

5. Key performance indicators to measure the effectiveness of steps being taken

This year MA has achieved to:

• Check 100% of its Supplier against the PSL process.
• Work with 100% of Clients which codes of conduct meet MA values
• Train 100% of its employees on modern slavery issues

6. Training on modern slavery and trafficking

All staff are expected to comply with all laws and act in accordance with local guidelines and regulations. We are undertaking to launch a compliance program to review our policies and procedures to ensure our colleagues have access to any additional information and support they may require with regard to human trafficking, forced labour, servitude and slavery.

We have strengthened our Learning and Development Team by adding additional resources, so our employees are better trained. MA is reviewing its corporate responsibility strategy as well by offering new platforms for volunteering in the communities. Training on modern slavery and human trafficking will be incorporated into existing training modules and available to all employees.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and constitutes MA slavery and human trafficking statement in respect of its 2020 financial year.

Document approved by board of directors on 3rd September 2021