MODERN SLAVERY STATEMENT

1: Opening statement from senior management

Svella Plc and its subsidiaries are committed to preventing acts of modern slavery and human trafficking from occurring within their business and supply chain and imposes the same high standards on their suppliers.

This statement is made at the end of the first year of trading for the Svella group of companies and provides the baseline from which we will endeavour to continually enhance our commitment to combatting modern slavery and human trafficking in our business and supply chain. This statement further sets out the key strategic initiatives that we have established in this first year of trading that will support the group in achieving these objectives.

2: Structure of the organisation

Svella Plc acquires controlling interests in distressed and underperforming businesses, or those in exciting growth sectors, and with its dedicated and focused management approach, Svella aims to improve performance to deliver returns for all stakeholders. 

This statement is made in respect of Svella Plc and its subsidiaries, which specifically includes Svella Connect Limited, a provider of digital infrastructure solutions.

Svella Plc and its subsidiaries together employ over 800 people and in the most recent consolidated audited accounts (being a condensed financial period of 7 months for its trading entities), the group reported a turnover of over £43m. The business operations of the Svella group are all entirely within the UK. To find out more about the nature of our business please click www.svella.com and www.svellaconnect.com

In order to deliver the services to its customers, Svella Connect Limited has an established supply chain of subcontract labour suppliers and civils construction contractors.

3: Policies

The Svella group policies will be reviewed by all key stakeholders across the business to ensure that they are fit for purpose to adequately seek to prevent modern slavery and human trafficking in the group as it commences its ambitious growth strategy. 

4: Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we are adopting a number of due diligence procedures which include thorough supplier onboarding procedures comprising, where appropriate and applicable, site visits and accreditation/ certification verification, periodic and ad hoc supplier visits and audits, collation and continuous updating of supplier registers and internal and external training.

Our procedures are designed to:

• establish and assess areas of potential risk in our business and supply chains

• monitor potential risk areas in our business and supply chains

• reduce the risk of slavery and human trafficking occurring in our business and supply chains

• provide adequate protection for whistleblowers

5: Risk and compliance

The Svella group regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain through its regular reviews and analysis of its supply chain both at an operational and board level.

We do not consider that we operate in high risk sectors or locations because all of our operations are delivered solely in the UK. Our labour supply chain is also all UK based and relies on skilled labour from a core group of suppliers that we look to establish long term trusted partner relationships with. 

Where we have identified a potential risk, for example the requirement to quickly resource new projects, we seek to mitigate this as much as possible by preferring to directly employ the labour resource. 

We ensure all our suppliers adhere to our policies and standards. We enforce a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find any gross failure to comply with our policies, including those relating to modern slavery or human trafficking in our supply chain we will immediately seek to terminate our relationship with the relevant supplier.

6: Effectiveness and KPI

The Svella group is committing to investing in best in class systems to improve the efficiency and productivity of its business. The immediate focus is on implementing systems within Svella Connect Limited that can also be utilised by the rest of the group. The systems will enhance supplier onboarding and audit processes, collate required records and provide real time data across the business regarding the delivery of its operations and the suppliers and labour involved in those processes. This will enable the business to have control and immediate knowledge of any points of concern to enable it to be proactive in the prevention of modern slavery and human trafficking within its business and supply chain.

Upon implementation of these systems, the business will be better placed to report on its data and analyse any trends from which to establish any key performance indicators against which it can measures its success in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains. 

7: Training

We are investing in educating our staff to recognise the risks of modern slavery and human trafficking in our business and supply chains. Through our training programmes, employees and stakeholders will be encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. This training will be a combination of remote e-learning modules curated by our specialist training provider, and in-person training for new starters and existing employees at induction sessions and refresher training.

8: Further actions and sign-off

As aforementioned, this is the first statement of the Svella group following its commencement of trading in 2021. Over the next year the Svella group is committed to further preventing modern slavery and human trafficking in its business and supply chain by: reviewing and revising its internal policies, implementing best in class systems and rolling out training to employees and other stakeholder.

This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement for the financial year commencing 1 May 2021 and ending on 30 April 2022 for Svella Plc, on its own behalf and that of its subsidiaries, including Svella Connect Limited (whose financial year commenced on 5 October 2021).

This statement was approved by the Board of Directors of Svella Plc

Andrew Tinkler

Executive Chairman

Svella Plc

Date: 31 October 2022