Swanntech | Modern Slavery Statement
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Modern Slavery Statement for the 2017 financial year

This statement is in response to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps that Swanntech Investment is taking to ensure slavery and human trafficking is not taking place in our supply chains or in any part of our business.

Our commitment

Swanntech Investment is committed to maintaining and improving our practices to combat slavery and human trafficking violations related to our own operations, our supply chain, and our services. We have zero tolerance towards slavery and human trafficking and expect our supply chain to comply with this


Risk assessment

We have carried out an independent third party modern slavery risk assessment of our supply chain and identified those categories of spend in which there is a relatively higher risk of modern slavery occurring – these are:

  • Paper and paper based products
  • Electrical equipment
  • Construction
  • Cleaning products and other chemicals

In addition, we have identified a number of sectors, which have an elevated risk relative to the rest of our supply chain but are themselves are low risk. These are: hotels and telecoms.

Our policies

We have a set of existing policies in place that are relevant to managing the risk of modern slavery and promotion of wider decent working practices. These policies are reviewed on an annual basis and adapted as required to our business. The scope and content of these policies are informed by the context in which we operate; our sector is a relatively low risk one for human rights risks in the supply chain.

  • Whistleblowing policy – our whistleblowing policy encourages and enables staff to report anything of concern and explains how they can do so confidentially
  • Equal opportunities
  • Living wage employer
  • Stewardship


Since 2017 Swanntech Investment has been working to establish a set of objectives to improve and refine our approach to ensuring that slavery and human trafficking are not taking place in our supply chains. This is a three year plan and is a key component of the development of our wider sustainability strategy.

We have develop a prioritised action plans for engagement with suppliers and key internal stakeholders in those categories with an elevated risk of modern slavery and will be rolling this plan out over the next 12 months. This plan includes:

  • The roll out modern slavery awareness training for our key procurement leads
  • The establishment of a code of conduct for working with established suppliers
  • The Introduction of a modern slavery screening approach into our on-boarding process with new, material suppliers
  • The communication of our commitment and policies to suppliers and staff

Steve Weiss, Chief Executive Officer

This statement was approved by the board of directors on 12 February 2018.