Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending December 2020.

Paragon Micro UK (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing modern slavery and human trafficking violations in our own operations, our supply chain, and our products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational Structure

Paragon Micro UK is the subsidiary of Paragon Micro, Inc. and has business operations in the United Kingdom and Europe.

We operate in the information technology sector. The nature of our supply chain is as follows:
We work with a number of key direct suppliers, who provide us with goods, such as outsourced business processes, IT software and marketing services.

For more information about the Company, please visit our website: https://paragonmicro.co.uk/

Policies

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

Recruitment and selection policy -

Paragon Micro UK operates a workplace culture that is protective of our employees’ human rights. We remain vigilent throughout our recruitment and onboarding process to identify and prevent potential cases of modern slavery or human trafficking.

Supplier code of conduct -

As an international business with suppliers and representatives across the world, we accept that we have a duty to trade responsibly and ensure all affiliates live up to our values and standards.

Staff code of conduct -

Company employees are bound by their contract to follow our Employee Code of Conduct while performing their duties. All employees must protect our company’s legality and comply with all environmental, safety and fair dealing laws. We do not tolerate any kind of discriminatory behaviour, harassment or victimisation. Employees should conform with our equal opportunity policy in all aspects of their work, from recruitment and performance evaluation to interpersonal relations. We prohibit briberies for the benefit of any external or internal party.

Procurement policy -

Paragon Micro UK requires all staff and volunteers, regardless of their role and for all procurement whatever the value, to follow the procurement principles of fairness, transparency, ethical behaviour, compliance and value for money. Procurement activity must not support organisations involved in criminal activity such as fraud, corruption, forced labour and other human rights abuses.

We ensure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of modern slavery or human trafficking occurring in our supply chains, we have adopted due diligence procedures.

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains.
• Reduce the risk of modern slavery and human trafficking occurring in our business and supply chains.

Risk and Compliance

Paragon Micro UK has evaluated the nature and extent of our exposure to the risk of slavery and human trafficking occurring in our UK supply chain. Due to the nature of our business, we assess ourselves to have a low risk in our business, because the majority of our supply chain is based in the UK and in low-risk industries, such as internet software and services.

We do not tolerate modern slavery or human trafficking or any other violation of human rights in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

Effectiveness

As part of our work for the next financial year, we will be considering how best to monitor the effectiveness of the actions taken.

ANTI-BRIBERY STATEMENT

We are committed to carrying out business in a transparent way, applying the highest standards of ethical conduct and integrity.

Bribery is defined within the Bribery Act 2010 as a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Under no circumstances is the giving, offering, receiving or soliciting of a bribe acceptable and we will not tolerate this in any form. This applies to all employees, affiliates and volunteers, together with any external agents working or acting on our behalf.

We have a zero-tolerance approach to bribery and a commitment to the Bribery Act 2010. Any instances of non-compliance will be dealt with firmly and, in addition to possible internal disciplinary action, it is noted that a criminal offence under the Bribery Act 2010 could lead to up to 10 years imprisonment and/or an unlimited fine.

With regard to external parties, we will not do business with anyone who does not support our anti-bribery commitments, and we reserve the right to terminate any contracts where there is evidence of acts of bribery that have been committed.