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Modern Slavery Policy

1. Introduction

This statement sets out Zoocha's actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 December 2023. The reason for this shorter financial year is that we have changed our financial year end; next year will run from 1 January 2024 to 31 December 2024.

As part of the software development sector and the wider technology industry, Zoocha recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Zoocha is absolutely committed to preventing slavery and human trafficking in all its activities, and to ensuring that its supply chains are free from slavery and human trafficking.

2. Organisational Structure and Supply Chains

This statement covers the activities of Zoocha Ltd (UK) and Zoocha SL (Spain):

  • Zoocha was founded in 2009 in Hertford, UK
  • Zoocha are a digital agency specialising in the development of web based software for public and private sector organisations
  • The software focus is on open source technologies (in particular Drupal) where the supply chains and workforce are predominantly community based rather than corporate

2.1 Countries of Operation and Supply

Zoocha currently operates in the following countries:

  • United Kingdom
  • Spain
  • Brazil

The following is the process by which Zoocha assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • We recruit directly and we do not outsource or subcontract
  • Procurement follows our central (UK) procedures

2.2 Risk Assessment

Zoocha’s suppliers and partners are predominantly based in the United States and Europe and include the likes of Amazon Inc., Google Inc., Microsoft and Atlassian each of which have stated codes of conduct and ethics. We consider ourselves to be low risk, but we do perform supplier reviews based on risk profile when sourcing new suppliers. We source goods and services from reputable suppliers and the nature of the goods and services we do procure do not demand the types of labour at risk for slavery and human trafficking. We will not support a supply chain where we are aware of or have reasonable grounds to believe that slavery and human trafficking are taking place. We would terminate supply contracts in these circumstances, wherever possible.

2.3 Responsibility

Responsibility for Zoocha's anti-slavery initiatives is as follows:

  • Policies: Will Huggins (CEO)
  • Risk assessments: Sarah Bath (Office Manager)
  • Investigations/due diligence: Sarah Bath (Office Manager)
  • Training: Sarah Bath (Office Manager)

3. Policy

Zoocha believes that our culture has been a critical component to our success. We have invested heavily in building our team and ensuring that the type of people we employ and work with have the highest levels of integrity. In all our offices worldwide, Zoocha’s team celebrates diverse perspectives and backgrounds and above all, we respect each other. Our core values are:

Quality – we don’t outsource our core skills
Trust – open and honest communication
Value – we are transparent about our cost structure
Success – our clients success is our measure of success

Our culture, underpinned by these values help us to ensure that each member of our team would have zero tolerance towards any sort of modern slavery or human trafficking. We strive to act ethically and with integrity in all our business relationships and we take great effort to implement and enforce effective systems and controls, including those that would prevent slavery and human trafficking from existing in the supply chains.

4. Due Diligence

Zoocha seeks to work with partners and suppliers who share our culture and values and enter into appropriate partner agreements with all our partners and suppliers. We require our partners and suppliers to comply with all applicable laws, which includes the UK modern slavery act.

As we grow and operate in more geographical areas with differing laws, cultures and values, we realise that there is an increased risk that must be assessed and mitigated. Our approach to this increased risk includes:

  • Attracting and training staff in each local jurisdiction to ensure the Zoocha culture and values are embedded
  • enhancing information, training, and communication systems to ensure that employees are well-coordinated, well-informed, and can effectively communicate with each other, our partners and suppliers and our customers
  • when entering into new contracts, we undertake due diligence to ensure that the third parties have the relevant policies and procedures in place that would prevent slavery, human trafficking, and forced labour.

Zoocha believe that no individual should be subjected to any form of forced labour, slavery, or human trafficking and we will continue to review our processes to take necessary steps within our power to prevent it from existing within its supply chains.

5. Effectiveness and Performance

Zoocha use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • provide adequate training for all staff
  • require suppliers and partners to be bound by obligations to comply with all applicable laws
  • regularly evaluate processes to determine whether it would be appropriate to adopt further policies or procedures

Throughout the financial year starting 1st April 2023, Zoocha have

  • continued to make this policy available to our team, partners and customers
  • undertaken training efforts related to this policy for staff involved in procurement, including with respect to audits of suppliers and appropriate terms for inclusion in negotiated agreements
  • continued to evolve our purchasing policy so that there is improved guidance around matters concerning this policy
  • increased efforts to include in all supplier agreements provisions that require suppliers and partners to comply with all applicable laws, including those that would prevent slavery and human trafficking from existing in the supply chains

Ongoing efforts to ensure that slavery and human trafficking is not taking place in any part of our business or supply chain, include:

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Zoocha’s slavery and human trafficking statement for the financial year ending 31 December 2023.