Modern slavery policy statement

Updated 17 February 2023

Our Commitment

Modern slavery is a serious crime and a violation of fundamental human rights. Modern slavery can occur in any business section and it takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking. All of which have the deprivation of a person's liberty to exploit them for personal or commercial gain in common.

We have a zero-tolerance approach to modern slavery and are committed to taking effective steps to eradicate modern slavery within our supply chain and business. We ensure that Smart acts ethically and with integrity in all of our dealings and relationships by implementing effective and transparent systems and controls. We maintain the same standard for our suppliers, contractors and other business partners.

Structure and Supply Chains

Given the nature of our business, our procurement spend is focused primarily on IT, office and professional services and therefore we believe the risk of modern slavery in our supply chain to be low. Although the risk is low, through our supplier risk management process we endeavour to safeguard that slavery, forced labour, human trafficking and child labour do not take place in our supply chain.

Smart expects its suppliers to act ethically by eliminating modern slavery and ensures this by conducting effective supplier due diligence. We continually review our supplier onboarding process, with existing suppliers being reassessed on contract renewal.


We are committed to ensuring we have up to date and relevant policies. Our Modern Slavery Policy is reviewed and updated annually to ensure alignment with current business status.

Education and Awareness

We believe in continuous education and in ensuring that our staff are equipped with the right tools and training to be effective in their roles. A detailed course on Modern Slavery is offered to new joiners, highlighting the importance of identification and reporting, along with definitions, signs to look out for, and common red flag indicators. It is also part of our annual core mandatory training modules.

Employees have access to all policies and will be required to read the Modern Slavery policy and attest to this.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is signed and approved by the Chief of Staff on 18 January on behalf of the board of directors. For more information please contact the Risk and Assurance team at