Modern Slavery refers to the deprivation of fundamental human rights, including freedom from forced labour and the right to liberty, for the purpose of personal or commercial gain. An abhorrent crime, which affects the world’s most vulnerable people. 

At Proxima, we embrace, support and respect the human rights of everyone we work with. We do not use, or accept, forced, bonded or involuntary labour or child labour. We only employ people who choose to work freely and respect their rights to equal opportunities and freedom of association. 

Our operations and supply chains

As a world-leading procurement and supply chain consultancy, Proxima works alongside some of the world’s largest and most successful businesses to help them spend their money wisely. We do this through an extensive suite of procurement consultancy services focused on cost transformation, supply chain sustainability, and decarbonization. We are famous for our delivery as experienced specialists, immersed in your business, accelerating outcomes.

Proxima is in a position to not only evaluate our own supply chain risk, but also the risk within our clients’ supply chains. Our constant interaction with clients’ suppliers enables us to positively influence risk assessment and provide insight on best practices to eliminate or reduce risk of Modern Slavery.

Our approach to Modern Slavery

Our colleagues have access to information sources on the complex topic of Modern Slavery, which provides a guide to ethical business conduct and the minimum standards of behaviour expected of our colleagues. This includes the Proxima Employee Handbook, Business Ethics Policy, Anti-Bribery and Corruption Policy, Corporate Social Responsibility Policy, Equal Opportunity Policy, Harassment and Bullying Policy, Health and Safety Policy, and Right to Work Guidelines. Colleagues are expected to comply with these at all times and suppliers are expected to follow their business’s corresponding policies which must be in alignment with our own.

For Proxima employees we are committed to providing appropriate pay, benefits and terms and conditions of employment and to review and update annually, where required, to meet business objectives.

The Proxima procurement terms and conditions state that suppliers shall comply with all applicable laws, regulations and actions relating to Modern Slavery and human trafficking, wherever we do business, including but not limited to the Modern Slavery Act 2015.

Our assessment and management of Modern Slavery risk

Whilst we consider our supply is generally at low risk of exposure to Modern Slavery and human trafficking the policies set out that where such increased risks are highlighted, supplier evaluation and due diligence shall be performed proportionate to the risk identified. We have committed to evaluating, and making a record of, our major suppliers’ published statements on Modern Slavery on an annual basis. We are satisfied that our major suppliers are taking appropriate actions to manage and mitigate risk of Modern Slavery in their supply chains but continue to monitor closely.

We recognise that ethical and productive partnerships with our suppliers strengthen our business, and our reputation. We treat our suppliers fairly and with respect, and we expect them to know and to agree to uphold our high standards of compliance and ethics.

We expect our employees to act diligently when selecting suppliers and suppliers are required to work in compliance with the Proxima procurement terms and conditions and within the guidelines and policies that have been established.

Modern Slavery training

To reflect our commitment to managing the risks of Modern Slavery, we will develop training that brings awareness of Modern Slavery and our influence in identifying risks for our clients by the end of 2022. This will become an integral part of our induction process for all new joiners and will be given to all current colleagues as mandatory training. We will regularly refresh this training and provide annual updates across the business. Our current policies are available for all colleagues to review at time of induction and on the company intranet for ease of access.

Reporting issues

In addition to the reporting of Modern Slavery risks in the procurement process, we provide our employees with a whistleblowing policy if they have any concerns or suspect any wrongdoing. Such concerns are investigated promptly and impartially. 

Our plans for the next 12 months

  • Develop training on awareness of Modern Slavery in supply chains for all colleagues
  • Conduct internal review of Modern Slavery policy and updates
  • Conduct an internal audit of our suppliers’ Modern Slavery policies and diversification

Closing statement

This is the first version of Proxima’s Modern Slavery Statement and is made pursuant to section 54(1) of the Modern Slavery Act 2015 and establishes as our slavery and human trafficking statement for the financial year ended 31 December 2021.

Approved by the Board of Directors of Proxima Group on 27 June 2022.

Michael Gartska