Modern Slavery Statement
A) Organisation
The statement is mainly applied to all the entities which belongs to Gateway Educonnect and also referred as “Group” in this statement.
B) Organisational Structure
The holding company of Gateway Educonnect is called Gateway Educonnect Investment Pte Ltd and it include Gateway Educonnect and other companies in UK, India, Australia and USA. The board in control of the Gateway Educonnect group is that of the Gateway Educonnect Investment Pte Ltd which has quarterly meetings, both executive and non-executive directors, and a nominated Chairman.
Gateway Educonnect assists organisations intending to Explore, Enter and Expand to vibrant global markets. Such activities can generally be classified as advisory and continuing-help activities. The work is largely unseasonal, except for peaks in activity driven by local financial, accounting, compliance, and HR regulations in the markets where we operate.
The labour provided to the Gateway Educonnect group in the course of conducting its operations is performed in the UK, India and the USA. The staff of Gateway Educonnect periodically travels both nationally and overseas as needed.
C) Definitions
The Gateway Educonnect feels that modern slavery involves:
- Forced work, through mental or physical threat
- Human trafficking
- His/her/ their ownership or control by the mental or physical abuse or threat of abuse of the employer
- Making you dehumanised, a commodity or buying or selling you as property
- pinned down physically or put under some restriction of liberty of movement.
D) Commitment
The responsibilities that will be identified by Gateway Educonnect as pertaining to the problem of modern slavery will be followed in the provisions of the Modern Slavery Act 2015. Gateway Educonnect understands that this will require it to constantly review internally, on the practices by the organisation on its labour force, and its supply chains.
Gateway Educonnect does not engage a business with another organisation anywhere in the United Kingdom or outside, which is knowingly a party to or found guilty of engaging in slavery, servitude and forced or compulsory labour.
None of the labour that is given to Gateway Educonnect, in the form of services of its own, is acquired through slavery or human trafficking. Gateway Educonnect strictly complies with minimum standards in relation to its role under applicable employment laws in the UK, India and the USA and, in most instances, goes beyond those standards in relation to its employees.
E) Supply Chains
To fulfil its activities, Gateway Educonnect’s main supply chains include those related to the supply of services to run the business (e.g. HR services, premises, marketing, technology, finance and admin) or services required to supply clients (e.g. market entry and support services in countries in which Gateway Educonnect does not have a business).
F) Potential Exposure
Since the problem of slavery and human trafficking can potentially be broken in terms of the supply of labour within a country where there might be minimal protection against violations of human rights, Gateway Educonnect takes this risk as its primary concern.
All in all, Gateway Educonnect feels that it has been relatively low regarding slavery/human trafficking exposure. But it has tried to make sure that its business or that of any other organisation that furnishes to its goods and/or services does not practice.
G) Steps
Gateway Educonnect carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
Gateway Educonnect has completed the following actions in line with section 54(4) of the Modern Slavery Act 2015 and ensured that modern slavery is not occurring:
- Re-examination of supplier contracts to provide the ability to terminate contracts in cases where the supplier is, or has the tendency to be, engaging in modern slavery.
H) KPI (Key Performance Indicators)
The following key performance indicators have been defined by Gateway Educonnect to understand its efforts to make sure that there is no modern slavery in Gateway Educonnect or its supply chains.
Periodic engagement of ‘at-risk’ staff via Gateway Educonnect’s Human Capital Team’s regular Employee Relations activity
I) Policies
The Gateway Educonnect policies contain policies explaining further how it approaches dealing with the issue of modern slavery:
- Recruitment policy
- Code of conduct
J) Training
The following training will be used by Gateway Educonnect to its employees to ensure that it makes its promise of making a difference in modern slavery a reality:
- Training of our Human Capital and Admin Operations teams at Indian on the modern slavery policies on human capital issues.
K) Slavery Compliance Officer.
Gateway Educonnect has a Slavery Compliance Officer to whom all issues related to modern slavery can be reported, and then the pertinent action will be taken in this respect in relation to the obligations of Gateway Educonnect.
- This is in recognition of this statement in the Modern Slavery Act 2015, Section 54(1), which needs to be reviewed every financial year.