Modern Slavery Policy and StatementDocument Ref: 5168-G-Modern Slavery StatementVersion 1.4 - Issue date: 25 November 2020

MODERN SLAVERY POLICY

Ark Data Centres Limited (“Ark”) is committed to operating with due respect for human rights and a desire to support ethical development through our business activities. We work with our supply chain to ensure that we comply with our obligations under the Modern Slavery Act 2015.

We are fully committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our supply chain. We take and expect a zero-tolerance approach to modern slavery from all of our contractors, suppliers and other business partners, and have introduced contractual provisions to prohibit the use of forced, compulsory or trafficked labour.

We publish a statement on our website each year, which sets out the steps we have taken to ensure that there is no slavery or human trafficking in any part of our business or supply chain. Any incidences of modern slavery will be dealt with robustly and we will cooperate with the relevant authorities to ensure it is dealt with to the full extent of the law.

The Senior Leadership Team has overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations. Ark is committed to ensuring that all Ark employees receive the appropriate training to ensure that they are able to identify potential incidences of modern slavery in the content of this policy with the aim of stamping out such practices.

 

MODERN SLAVERY STATEMENT

1. Overview

1.1. This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Ark Data Centres Limited (“Ark”) and subsidiary companies during the year ending 30 June 2020 to prevent modern slavery and human trafficking in its business and supply chain.

2. Introduction

2.1. Ark seeks excellence in every aspect of its business and strives to ensure the highest standards of professionalism, integrity, and ethical business practice. We are committed to lawfully conducting our business and this includes engaging with our suppliers to ensure that they share our high standards.

2.2. We fully support the objective of the Modern Slavery Act of 2015, which requires businesses to set out what steps they have taken during the financial year to ensure that modern slavery is not occurring in their supply chains and their organisation.

3. Structure of the Organisation

3.1. Ark was established in 2005 to offer secure and efficient data centres within purpose-built campuses. We empower businesses to work from anywhere in the world by designing, building and operating data centres that lead the market in social responsibility. Our pioneering facilities leverage 100% renewable energy, optimum security, high availability, and offer world-class sustainable scalability.

3.2. We deliver solutions to a wide variety of industries and business sectors, including cloud companies, the public sector, regulated markets, service providers and telecommunications businesses.

3.3. Ark has established several key partnerships and alliances, with suppliers, providers, and service partners – all chosen because they actively contribute to a key aspect of our operations. We foster long-term relationships with these key partners and avoid making demands that might lead to them violating human rights.

4. Policies

4.1. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chain or any part of our business. Our modern slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships in addition to implementing effective due diligence to ensure that modern slavery is not taking place anywhere in our supply chain.

4.2. We operate a Whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

4.3. Our Health & Safety policy sets out Ark’s commitment and approach to providing and promoting a safe and healthy working environment.

4.4. We conduct all business honestly and ethically. Our Anti-Bribery & Corruption Policy details our zero-tolerance approach to bribery and corruption and commitment to acting professionally, fairly, and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. This policy applies to all individuals working for or on behalf of Ark in any capacity.

5. Supply Chain Management

5.1. To ensure that the wider Ark service offering is following the direction of the policy on aspects of Modern Slavery, Ark has placed a flow-down obligation on all suppliers of services and goods whereby the provisions of the Modern Slavery Act are a contractual obligation. This will ensure that any future statements made by Ark are supported by relevant facts, information, and accounts from our supply chain so that Ark can be confident of child and forced labour use within our supply chains.

5.2. We have implemented a risk-based approach to identify, prevent, mitigate, and account for how Ark addresses threats of modern slavery and human trafficking. We have taken steps to assess the actual and potential human rights impacts by conducting due diligence on a sample of our direct suppliers. These suppliers were asked to complete the Modern Slavery Supplier Survey intended to understand the risk of modern slavery in their supply chain and the actions being taken to address this risk. We did not find any evidence of non-compliance throughout the evaluated supply chain against the Modern Slavery Act 2015.

5.3. The results of the survey were compared to the data from previous assessments to identify any trends. This analysis has enabled Ark to identify areas where the supply chain is performing well and where there are opportunities for improvement. This evidence informs decision making and will influence our engagement with suppliers in the future.

5.4. We have also completed additional reviews of the statements published by our key suppliers and partners. This exercise has provided Ark with further assurances that our supply chain is taking effective action to meet the requirements of the Modern Slavery Act 2015.

6. Training & Awareness

6.1. High levels of awareness across Ark is key to the company’s success in ensuring that modern slavery is targeted more effectively and persistently.

6.2. Ark’s Modern Slavery Policy has been communicated to all staff and reinforces the Senior Leadership Team’s commitment to ensuring that modern slavery is not taking place anywhere in our operations and supply chain.

6.3. Additional information regarding modern slavery is available to all staff on Ark’s intranet. The purpose of this resource is to provide staff with a more detailed understanding of modern slavery and help individuals identify signs of modern slavery. It also includes information on whom staff should contact should they have any concerns.

6.4. We also provide employees with guidance on modern slavery as part of our induction program, which sets out Ark’s commitment to tackling modern slavery and what employees should do if they identify a potential case of modern slavery.

6.5. Staff are encouraged to report any concerns or suspicions regarding the presence of modern slavery.

7. Exposure to slavery and human trafficking

7.1. We have considered the risk of Ark being exposed to slavery and human trafficking, taking into consideration:

7.2. As a result of the factors above and noted elsewhere within this statement, we deem the risk of slavery or human trafficking occurring within our business and direct supply chain to be low.

8. Governance

8.1. Ark shall take responsibility for this statement which will be reviewed and updated as appropriate.

8.2. This statement was approved by the Senior Leadership Team on the 17th November 2020 and has been signed by the Commercial Director, on behalf of the Senior Leadership Team.

 

Simon Burrage
Commercial Director
Ark Data Centres Limited
25 November 2020