Modern Slavery and Human Trafficking Statement January 2022
Service Express Europe Limited (formerly Blue Chip Customer Engineering Limited) and its subsidiaries (“Service Express”) have a zero-tolerance approach to slavery and human trafficking of any kind, perform regular due diligence across all new and existing suppliers as well as maintaining strict policies for its own business operations covering recruitment and management of all permanent and temporary employees. This statement provides more detail of the business and related measures.
About Service Express
Blue Chip Customer Engineering Limited and its affiliates were acquired by Service Express Incorporated of Grand Rapids, Michigan, U.S.A. on 29th January 2021 and renamed Service Express Europe Limited on 17th December 2021. During 2021 Service Express Europe was expanded with the acquisition of U.K. based companies ICC Northern U.K. Limited and ICC Managed Services Limited.
Founded in 1987 as a provider of IBM hardware maintenance services, Service Express has grown organically to be the largest independent provider of IBM support services outside of IBM and is now a leading provider of data centre and multi-vendor support services across all industry sectors with an employee headcount of 296 at the end of 2021, mostly based in the United Kingdom.
Service Express also has a fully owned subsidiary based in Sri Lanka focussed on providing in house software development capabilities and basic operational support for selected customers to enable managed service delivery 24 hours a day 365 days a year.
Our Business Operations
Service Express has built its business based on the provision of total system support services for users of IBM technology, including hardware maintenance and disaster recovery services, software support, and managed infrastructure services based out of the company’s two data centres located near Bedford in the United Kingdom. Service Express also provides hardware, software, and professional services to assist customers who have not outsourced their information technology environment.
Whilst currently focussing on the United Kingdom as a core market, including local entities for multi- national organisations, Service Express is continuing to expand its hardware maintenance operations into Europe, placing more emphasis on effective use of a supply chain. The objective of our supplier relationship function is not only to ensure service quality and performance, but to ensure supplier commitment to our policies and business practices, irrespective of geography.
Supplier relationship remains key to the above achievements and reports directly into the Senior Leadership Team as part of ensuring appropriate Director level sponsorship. Service Express is also proud of its multi-cultural employee base, and we continue to provide opportunities in the U.K. for staff from our Sri Lankan office as well as developing the skills of those new to employment with our apprenticeship programmes that include competitive salaries and Service Express funded education.
Our Supply Chains
The Service Express supply chain is broadly broken into several categories including new product supply (of hardware or software), used product supply (for hardware spares and second user sales), connectivity services, specialist technical support services, utility services (such as power), outsourced back-office functions, logistics and transport suppliers, and facility services such as cleaners.
Within the above Service Express has relationships with companies that service its customers as well as internal business operations. With the expansion of hardware maintenance operations into Europe, we do not just perform remote assessments of potential new partners and suppliers, we make onsite visits part of our supplier take on due diligence, where applicable.
Our Approach to Modern Slavery and Human Trafficking
Service Express continues to have a zero-tolerance approach to slavery and human trafficking. Irrespective of whether a supplier is U.K. based or not, we require a contractual commitment to allow us to audit their business and (where applicable) an explicit obligation to abide by local legislation regarding slavery and human trafficking, ensuring there is no confusion as to the standards we expect from our supply chain.
Following the acquisition of the ICC group of companies, focus is being given to integrating employees, defining the new company organisational structure and standardising company policy and processes based on those already in place for Service Express. The integration will additionally include identifying new suppliers to Service Express and where applicable, performing due diligence as part of confirming any future relationship and ensuring they adhere to our policies.
Our Policies on Slavery and Human Trafficking
Modern slavery refers to servitude, forced labour and human trafficking. Service Express recognises this as a worldwide problem that can occur in any country, including the United Kingdom. We expect and encourage our employees to report any concerns and have a whistleblowing policy that ensures the confidentiality and anonymity of anyone reporting a violation they identify. All reports will be fully investigated, and appropriate remedial actions taken.
Our policies are maintained by our Compliance Team, have clear ownership, and are regularly reviewed. The expectation of our Senior Leadership Team is that they will be promptly made aware of any concerns regarding slavery and human trafficking and that management will act upon these reports accordingly. We also commit in our contracts with customers to assisting them with complying their reporting requirements under the Modern Slavery Act 2015.
The Service Express Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships with employees, subcontractors, customers, and suppliers. This includes maintaining and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain. This expectation is also set out in a Subcontractor and Supplier Code of Conduct which all members of our supply chain must sign up to.
Due Diligence Processes for Slavery and Human Trafficking
Service Express supplier management and Compliance functions provide an internal governance function on slavery and human trafficking at both operational and leadership levels. This governance structure is designed to identify, assess, and mitigate potential risk areas in our supply chain, perform due diligence, and provide a basis for the ongoing monitoring of risk areas, providing policies for suppliers to adhere to, and a clear process for issues to be reported confidentially.
The length of some supply chains adds complexity to due diligence and effort is made to recognise end to end of even the most extended chain, i.e.., not just the company supplying hardware, but labour used to extract raw materials used in manufacturing of hardware. This is achieved by reviewing a supplier’s own policies, records, and due diligence processes for its own supply chain, ensuring that contractual commitments can be demonstrated.
Having previously contacted our supply chain and collected copies of relevant policies, slavery, and human trafficking statements and/or a signed commitment to exclude slavery and human trafficking from their supply chain, as well as conducting a complete review and enhancement of our new supplier due diligence process, we continue to assess risk across our supply chain, specifically focussing on any new suppliers introduced to the supply chain as a result of the ICC companies being acquired.
Each company in the Service Express supply chain is required to notify us immediately on becoming aware of any indications of slavery or human trafficking in their business or supply chain, and we encourage a cooperative approach where issues are resolved together and proactively. Any suppliers in breach of its commitments will face appropriate actions which could include termination of contracts and its relationship with Service Express.
Supplier Adherence to Our Values and Ethics
Service Express Europe has a published Code of Conduct in the public domain on our website for suppliers and subcontractors that all such companies we work with are required to contractually commit to in accepting orders for goods and services from Service Express. This includes suppliers engaged on a transaction by transaction basis as well as those subject to longer term engagements.
The Code of Conduct addresses not only slavery and human trafficking obligations, but also ensures compliance to ethical business practices in general and commitment to climate friendly practices in general. The Service Express Europe Ltd Standard Purchase Terms referenced on Purchase Orders have also been updated so that ad hoc suppliers engaged on a transactional basis are also captured.
All Service Express Europe staff are notified whenever there is a significant change to a policy. Our recruitment process and policy also define our stance on slavery and human trafficking, both in making sure that new employees are aware of our policies and ensuring our employment packages are fair. To ensure continued understanding of topics such as the risk of modern slavery and human trafficking in our business and our supply chain, we provide awareness updates to staff on relevant enforcements by the courts and regulatory authorities, including in relation to the Modern Slavery Act 2015.
Our Effectiveness in Combating Slavery and Human Trafficking
Service Express uses a number of key performance indicators (KPI’s) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place on any part of the business or supply chain. The KPI’s are based on measuring the processes discussed earlier in this statement and include the number of suppliers contacted, the number that have signed Service Express contract terms, the number that have been visited or had due diligence performed, and additionally the number of related concerns that have been reported, whether through normal management channels or via the whistleblowing procedure.
The directors of Service Express are ultimately responsible for compliance by the company and this statement reflects a number of ongoing activities and initiatives made to ensure we are continuing to ensure that slavery and human trafficking in any of its various forms, does not occur in our business or supply chain. We will continue to refine and strengthen our efforts to combat slavery and human trafficking as Service Express grows further and strive to lead the way as a business that truly believes in ethical practices.