A) ORGANISATION
This statement applies to all companies within and associated to Gateway International (referred to in this statement as ‘The Group’).
B) ORGANISATIONAL STRUCTURE
Gateway International is the holding company for Gateway International’s group of companies, including entities in India, the USA, the UK and Australia. The Gateway International group is managed via the Gateway International Board which meets quarterly and is made up of both executive and non-executive directors and a designated Chairman.
Gateway International supports organisations looking to Explore, Enter and Expand into dynamic international markets. These activities can be broadly categorised into advisory and ongoing support activity. The work is largely unseasonal with the exception of peaks in activity as driven by local financial, accounting and compliance and HR regulations in the markets that we operate.
The labour supplied to the Gateway International group in pursuance of its operation is carried out in the UK, India and the USA. Gateway International’s team travel from time to time domestically and internationally as their role requires.
C) DEFINITIONS
Gateway International considers that modern slavery encompasses:
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Human trafficking
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Forced work, through mental or physical threat
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Being owned or controlled by an employer through mental or physical abuse or the threat of abuse
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Being dehumanised, treated as a commodity or being bought or sold as property
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Being physically constrained or to have a restriction placed on freedom of movement
D) COMMITMENT
Gateway International acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Gateway International understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
Gateway International does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to Gateway International in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. Gateway International strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK, India and the USA, and in many cases exceeds those minimum standards in relation to its employees.
E) SUPPLY CHAINS
In order to fulfil its activities, Gateway International’s main supply chains include those related to the supply of services to run the business (e.g. HR services, premises, marketing, technology, finance and admin) or services required to supply clients (e.g. market entry and support services in countries in which Gateway International does not have a business).
F) POTENTIAL EXPOSURE
Given the nature of our business, Gateway International considers its main exposure to the risk of slavery and human trafficking to be in the supply of labour in countries where protection against breaches of human rights may be limited.
In general, Gateway International considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
G) STEPS
Gateway International carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
Gateway International has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, Gateway International has taken the following steps to ensure that modern slavery is not taking place:
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Reviewing supplier contracts to include termination powers in the event that the supplier is, or is suspected, to be involved in modern slavery.
H) KEY PERFORMANCE INDICATORS
Gateway International has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in Gateway International or its supply chains.
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Periodic engagement of ‘at-risk’ staff via Gateway International’s Human Capital Team’s regular Employee Relations activity
I) POLICIES
Gateway International has the following policies which further define its stance on modern slavery:
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Code of conduct
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Recruitment policy
J) TRAINING
Gateway International provides the following training to staff to effectively implement its stance on modern slavery:
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For our Human Capital and Admin Operations teams in India, training on modern slavery policies.
K) SLAVERY COMPLIANCE OFFICER
Gateway International has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Gateway International obligations in this regard.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.