Ethics and Modern Slavery Policy

Updated at 2021-11-14

Structure, business and supply chain

186Kloud is a communications technology distributor

We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen. In that spirit, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it.

186Kloud Ltd is headquartered in London, United Kingdom and provides services throughout Europe, including the United Kingdom. Our range of services comprises representation of a range of communications and technology vendors of the highest standard. This allows us to focus our services and influence across the geographic markets covered by these vendors. Where possible, we engage suppliers who intern enable us to improve consistency in ethical practices throughout the supply chain.

As part of our commitment to engage an Ethical Trading Initiative, we have embraced the requirement to publish an annual slavery and human trafficking statement. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year. We regularly take the key steps to ensure slavery and human trafficking does not occur within our organisation or supply chain including as follows:


Ethics, Slavery and human trafficking policy

Our Ethics, Slavery and Human Trafficking Policy, continually focusses on the development of clear objectives for 1, 3 and 5 year plans around the following themes:

  • Relationships: Strengthening our supplier engagement process
  • Feedback: Establishing grievance mechanisms and channels for individual worker feedback
  • Knowledge: Improving our knowledge base by collecting relevant data and improving product traceability
  • Third party engagement: Building strategic alliances with independent social auditors, unions and NGOs
  • Measurable change: Developing verifiable KPIs to measure progress
  • Supplier collaboration: Encouraging suppliers to collaborate to address slavery and human trafficking issues
  • Incentivisation: Developing mechanisms to incentivise employees and suppliers to address slavery and human trafficking and improve labour standards
  • Accountability: Establishing a framework for organisation accountability to allow for raising issues, making suggestions, voicing grievances and reporting slavery and human trafficking

Due diligence procedures

We understand that our biggest exposure to Modern Slavery is in our service  supply chains, where we regularly undertake activity to minimise the risk of Modern Slavery. Within these areas, new suppliers are subject to due diligence checks in the form of compliance to own ethical standards of engagement. These audits are intended to identify any Modern Slavery practices. If issues are identified, appropriate investigative and remedial actions will be taken.


Identifying, assessing and managing risk

We set out to identify the extent of any slavery and human trafficking in our supply chains by:

Collaborating with our suppliers to develop an improvement plan to address new and previously identified slavery and human trafficking issues

Instituting an annual review questionnaire for existing suppliers to understand suppliers’ self-assessment of slavery and human trafficking issues, allowing us to better identify slavery and human trafficking issues as they develop over time and to collect supplier-provided data to track improvement in suppliers’ attitudes.

Key performance indicators

In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:

  • Staff training levels
  • Number of slavery incidents reported in the supply chain

Training available to staff

A key part of our slavery and human trafficking strategy is to promote cultural change through training. We regularly assess and review the development and availability of training around modern slavery issues for all staff