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Modern Slavery Statement

  1. INTRODUCTION

This statement applies to CMS Distribution (hereafter referred to as ‘the Organisation’, “we”, “us”, or “our”) and the requirement to publish statements in respect of our efforts to combat modern slavery in our own business and our supply chains. The information included in the statement refers to the Organisation’s financial year ending 31st December 2022.

  1. ORGANISTIONAL STRUCTURE

The Organisation is part of a group of companies supplying business and consumer technologies all over the world, employing over 430 people who work from our sites in the UK, Ireland, and the Netherlands.

The Organisation is predominately trade only and has dealings with thousands of corporate resellers, managed service providers, high street and online retailers ranging from large multi-nationals to smaller, independent IT companies. We represent more than 200 vendors.

Our vision is to be a sustainable ‘glocal’ business that connects people to innovative technologies and services, empowering our great people to exceed the expectations of customers and vendors.

  1. COMMITMENT

We acknowledge our responsibilities in relation to tackling modern slavery and commit to complying with the provisions in applicable legislation; the Modern Slavery Act 2015 in the UK, the Criminal Law (Human Trafficking) Act 2008 (an amended in 2013) in the Republic of Ireland, and the Child Labour and Due Diligence Law Act in the Netherlands.

We consider that modern slavery (“Modern Slavery”) encompasses:

  • Human trafficking into crime.
  • Forced work through financial, mental, or physical threat.
  • Being owned or controlled by through mental or physical abuse of the threat of abuse.
  • Being dehumanised, treated as a commodity, or being bought or sold as property.
  • Being physically constrained or to have restriction placed on freedom of movement.

We endeavour to engage with external parties who support key principles of the Ethical Trade Initiative (ETI) Base Code, founded on the conventions of the International Labour Organisation (ILO).

  1. SUPPLY CHAINS

Our main supply chains include those related to the supply of technology products, software and services for use by consumers and businesses, which extend across the world, predominately operating within Europe and the Far East. The majority of products are sourced directly from the brand owners.

Due to the nature and complexity of many of these products, we are cognisant our supply chain extends through primary suppliers to their suppliers and sub-contractors, where it might be difficult to verify compliance with our stated aims.

  1. POLICIES & DUE DILIGENCE

Our Employees:

We understand that our people are our biggest asset and as such shall treat all our employees in a fair, professional, lawful, and unbiased manner.

  • We provide fair compensation & benefits including heath care, safe working conditions and holiday entitlements. Our part-time or fixed-term employees receive the same benefits as our full-time or permanent employees, on a pro-rata basis.
  • Our salaries are market-related and salary review policies mean that pay can be reviewed at any stage of the year, or employee life cycle.
  • Our recruitment processes shall be robust and aligned to the relevant employment laws. This includes ‘right to work’ document checks; contracts of employment and checks to ensure everyone employed is aged 16 and above.
  • Our employment contracts shall be on a guaranteed hours basis only (no offers of employment are made on a zero-hour basis).

Supply Chains:

We continue to seek confirmation from new vendors (who work for us by providing products) of their own commitment to having no Modern Slavery within their own organisation. Where possible this confirmation will be contractual in nature.

  1. RISK ASSESSMENT & MANAGEMENT

We consider our exposure to modern slavery to be limited and the main risks to be the working conditions and treatment of employees in the product supply chain, especially in higher risk countries.

When engaging with a new vendor/supplier we seek confirmation from the vendor/supplier that they are operating to key principles of Ethical Trading Initiative (ETI) Base Code founded on the conventions of the International Labour Organisation (ILO) (or similar).

  1. PROPOSED ACTIONS FOR THE NEXT FINANCIAL YEAR

The Organisation has set the following key performance indicators for next year to increase our effectiveness in tackling Modern Slavery in our business and our supply chains.

  • Review Whistleblowing Policy and refresh internal procedure and training.
  • Request visibility of Ethical Audits from new vendors. Audit regimes we accept include SMETA, BSCI, SEDEX, ETI.
  • Request visibility of Ethical Audits from ‘High-Risk’ vendors.
  • Review and publish a Code of Conduct for our vendors.
  1. REPORT ON LAST YEAR'S PLANNED ACTIONS

During the last year we’ve hit our targets by:

  • Drawing up a new internal Modern Slavery Policy for use internally;
  • Introduced mandatory Modern Slavery awareness training for all new employees going forward, and a refresher for existing employees;
  • Obtaining recommitment to our principles from vendors we judged to be 'high risk' based on country-of-origin data cross referenced to World Bank Governance Indicators, and the Global Slavery Index. We achieved recommitment from the majority of such vendors (and work continues to gather the outstanding recommitment from those yet to respond).
  1. ENTITIES COVERED BY THIS STATEMENT

This statement applies to the following entities:

In the UK: CMS Distribution Limited, company registration number 2214562

In Ireland: CMS Distribution Limited, company registration number 193425

In the Netherlands: CMS Distribution B.V., company registration number 27310208

  1. QUESTIONS AND CONTACT INFORMATION

If you have any questions or concerns about this Statement or the practices of the Organisation, please contact us at: compliance@cmsdistribution.com

This statement is made in pursuance of the various legislation covering the Organisation’s activities and has been reviewed and approved by the Board.

Frank Salmon, Chief Executive Officer.

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Date: 30th June 2023