INTRODUCTION

This policy is made on behalf of Valcon Group UK and is informed by section 54(1) of the Modern Slavery Act 2015, comprising our slavery and human trafficking statement. 

Valcon is not obliged under legislation to set out a Modern Slavery statement (as the company falls below the thresholds under which one is obligated). However, the company still publishes this statement because: 

• Many of the client organisations with which we work are obliged to publish a statement and routinely enquire as to our position. 

• We are supportive of the principles of the Act and therefore seek to act within the spirit of the law and not simply comply with the minimum obligations. 

This policy should be read in conjunction with associated policies, in particular: 

• Recruitment 

• Whistleblowing 

• Company Values and Professional Standards. 

POLICY STATEMENT

MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FOR THE FINANCIAL YEAR 2025.

This statement is made on behalf of Valcon.

Modern day slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. order to exploit them for personal or commercial gain.

Our Business

Valcon is one of the world’s fastest-growing consultancies, delivering premium operations consulting merged with deep technology and data expertise. 

We have the full range of capabilities and expertise our clients need to give them a competitive advantage through people, processes, data, and technology. We weave these skills together in different ways to respond to new opportunities and challenges that deliver sustainable results. 

We are headquartered in the Netherlands with operations within the UK, Denmark, Sweden, Germany, Croatia, and Serbia, and services delivered internationally when required. As a consultancy within the professional services sector, it is not the view of the company that it operates in any markets or services that are likely to be considered high-risk. 

Statement

This Policy Statement affirms the commitment of Valcon to acting ethically and with integrity in all its business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking do not take place anywhere within its business and supply chains. 

DUE DILIGENCE PROCESSES FOR SLAVERY AND HUMAN TRAFFICKING

The Valcon Group UK Managing Partner is nominated to provide planning to identify risks and mitigate against such risks. The UK Managing Partner, in turn, works with others (notably within Human Resources, Recruitment and Operations/Commercial functions) and reports, as needed, to the Company Board. 

Our scrutiny and planning specifically: 

• Identify inappropriate employment practices 

• Mitigate the risk of slavery and human trafficking occurring within the business and the company supply chain 

• Identify, assess, and monitor other potential risk areas 

• Protect whistle-blowers 

Risk Assessment and Management 

Valcon undertakes periodic assessments to identify and evaluate potential modern slavery risks within its operations and supply chains. This includes escalation procedures for any identified risks, with documented mitigations and Board oversight where necessary. 

Due diligence findings and mitigation plans are reviewed at least annually and updated as required. 

SUPPLIER ADHERENCE TO ANTI-SLAVERY AND HUMAN TRAFFICKING

We have zero tolerance for slavery and human trafficking. 

To ensure all those in our supply chain and contractors comply with this policy, we operate in line with principles of responsible sourcing, including: 

• Ensuring employees are paid within the boundaries of the company’s pay policies, which in all cases exceed the prevailing minimum wage levels applicable under legislation 

• Ensuring employees’ work hours and holiday entitlements comply with the Working Time Regulations 

• Reviewing the company supply chain, through the tender process, supplier reviews, and self-certification declarations, to ensure compliance with the requirements of this policy 

• Including modern slavery clauses in all new supplier contracts, requiring compliance with the Modern Slavery Act and our policies. 

CLIENT ADHERENCE TO ANTI-SLAVERY AND HUMAN TRAFFICKING

Valcon is committed to only working for client organisations that support the principles of the Modern Slavery Act. 

Valcon commits not to work with any organisation where there are breaches, or grounds to suspect breaches, of the Act. 

POLICY AND PROCEDURE

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, supply chains, and business partners, we operate a clear policy and procedure that is set out in our company policies manual. 

This policy, among others, forms part of the Induction Training Process, and communications within our Employee Handbook, Manager Guide, and within our Intranet. 

TRAINING AND CAPACITY BUILDING 

Valcon provides training on modern slavery risks as part of its induction programme for all new joiners. Additional refresher training is provided periodically for staff working in procurement, recruitment, or operational functions exposed to potential risk areas. This ensures all employees understand how to identify and report concerns relating to modern slavery. 

EFFECTIVENESS AND KEY PERFORMANCE INDICATORS 

To measure the effectiveness of our actions in preventing modern slavery, Valcon will monitor: 

• The percentage of employees completing modern slavery awareness training 

• The number of reports or incidents raised and resolved through our whistleblowing or grievance channels. 

These indicators will be reviewed annually by the UK Managing Partner and the HR team. 

DECLARATION

This Policy Statement has been updated since the original publication in May 2022 and applies for the financial year ending 31st December 2025.

Marc Bervoets
Managing Partner
Valcon Group UK