UK Modern Slavery Statement
This statement outlines our commitment to preventing modern slavery and human trafficking in our operations and supply chains, in compliance with the Modern Slavery Act 2015.
Introduction
Hertzian Ltd is committed to combatting slavery and human trafficking in its business and supply chains, and we make this statement to assist with compliance with the Modern Slavery Act 2015. This statement relates to the financial year ending 31st March 2025.
As our business has a turnover of less than £36 million, we do not have a legal obligation to produce a modern slavery statement. However:
- We agree that exploitation within all supply chains ending in the UK is a blight on our society, and we are committed to playing our part in eliminating exploitation.
- We understand that customers with obligations under the Modern Slavery Act 2015 cannot comply with those duties without our cooperation.
To that end, we confirm that we have examined our own business and, to the extent that it is reasonably practicable, businesses within our supply chain and we confirm the following:
- We confirm that within our own business, no relevant offence relating to slavery or human trafficking has been committed.
- We have made enquiries of businesses that supply directly to us and we are confident that no relevant offence is committed in that business.
- Insofar as it was reasonably practicable, we have examined our supply chains and confirm that we found no evidence of slavery or human trafficking.
Further details about our business and supply chain are provided below.
Our Business
Hertzian Ltd is a technology company specializing in data analytics and software solutions for the gaming industry. Our business operates with a small, highly-skilled team based in our main office. We are a private limited company and do not have a complex group structure. We operate in the United Kingdom.
Our Supply Chain
Our supply chain consists of professional services, software licenses, IT hardware, and standard office supplies. We do not believe that our supply chain is in one of the sectors or geographical regions that entail a greater risk of exploitation.
Where it is reasonably practicable, we ensure that businesses in our supply chain have made a similar statement relating to slavery and human trafficking.
The person in our business responsible for assessing matters relating to slavery and human trafficking is: The Board of Directors.
We also encourage all employees to report on any matters relating to slavery or human trafficking in our supply chains of which they become aware.
Anti-Bribery and Corruption Policy
This policy outlines our commitment to preventing bribery and corruption, in accordance with the UK Bribery Act 2010.
Introduction and Scope
Hertzian Ltd is committed to the highest standards of integrity and ethical conduct. We have a zero-tolerance policy towards bribery and corruption and are committed to complying with all applicable laws, including the UK Bribery Act 2010. This policy applies to all employees, officers, agents, contractors, and any third party acting on our behalf.
Prohibited Conduct
Under no circumstances are you permitted to offer, promise, give, request, agree to receive, or accept a bribe. A bribe includes any financial or other advantage intended to improperly influence a person in a position of trust or to induce them to perform a relevant function or activity improperly. This applies whether the advantage is offered to or by a public official or a private individual.
Gifts, Hospitality, and Promotional Expenses
Reasonable and proportionate gifts and hospitality can be a legitimate part of doing business. However, they must never be offered or accepted with the intent to improperly influence a business decision or gain an unfair advantage. All gifts and hospitality must have a clear business purpose, be infrequent, and be recorded in our company's register. This includes gifts given or received, and hospitality provided to or by clients, suppliers, or other business associates.
Our Corporate Responsibility
The UK Bribery Act 2010 includes a corporate offense of failing to prevent bribery. As a company, we are responsible for ensuring we have adequate procedures in place to prevent bribery and corruption. We are committed to conducting due diligence on all third parties and business partners to ensure they meet our standards of ethical conduct.
Reporting Concerns (Whistleblowing)
We encourage all employees and stakeholders to be vigilant and to report any concerns of suspected bribery or corruption immediately. All reports will be handled confidentially and without fear of reprisal. Concerns can be raised with your line manager or directly to legal@hertzian.co.uk.
Breaches of Policy
Any breach of this policy is a serious matter and will be dealt with under our disciplinary procedures, which may result in dismissal. Furthermore, a breach may lead to personal criminal prosecution under the UK Bribery Act 2010, which carries a maximum penalty of 10 years imprisonment and an unlimited fine.
Environmental Sustainability Policy
Hertzian Ltd recognises that it has a responsibility to the environment beyond legal and regulatory requirements. We are committed to reducing our environmental impact and continually improving our environmental performance as an integral part of our business strategy and operating methods, with regular review points.
Responsibility
The Board of Directors is responsible for ensuring that the environmental policy is implemented. However, all employees have a responsibility in their area to ensure that the aims and objectives of the policy are met.
We take steps both internally and externally to show our commitment to reducing our environmental impact. Below is a summary of our actions:
Waste Management
- We will reduce the amount of waste produced and recycle where possible.
- We will prevent the release of pollutants that can cause environmental damage.
- We will use digital documents and avoid printing to minimize paper waste.
Office Supplies
- We will evaluate the environmental impact of any new products we intend to purchase.
- We will prioritize purchasing office supplies from certified sustainable sources.
Monitoring and Improvement
- We will continually improve and monitor our environmental performance.
- We will set and track annual goals for reducing our energy and waste consumption.
Maintenance and Office Cleaning
- The cleaning materials we use will be checked to ensure it's as environmentally friendly as possible.
- We will work with contractors who use green cleaning products and methods.
Energy
- Lights and electrical equipment will be switched off when not in use and our heating will be adjusted with energy consumption in mind.
- We will use energy-efficient appliances and minimize reliance on air conditioning.
Our People
- We will increase employee awareness through training.
- We will involve staff in the implementation of this policy, for greater commitment and improved performance.
- We will promote remote working to reduce employee commute-related emissions.
Water
- We will avoid water wastage wherever possible.
- We will install low-flow taps and toilets where feasible.
Chemicals and Hazardous Substances
- Wherever possible we will substitute substances that are harmful to the environment with those that have less of an impact.
- We will dispose of all electronic waste (e-waste) through certified and environmentally responsible channels.
Legal Duties
- We will keep up to date with changes in environmental law and ensure we are fully compliant with our duties.
- We will maintain records to demonstrate compliance with all relevant environmental regulations.
Transportation
- Where possible, we’ll promote the use of alternatives such as email or video/phone conferences.
- We’ll reduce the need to travel, wherever possible.
Customers, Suppliers and Other Stakeholders
- We will work with suppliers, contractors and sub-contractors to improve their environmental performance.
- We will promote and partner with suppliers who have robust environmental policies.
Contractors
- We will work with contractors who are equally as committed to reducing their environmental impact.
- We will review the environmental policies of potential contractors before engaging their services.
Equality and Diversity Statement
Our commitment to fostering a diverse and inclusive workplace where every individual is valued and treated with dignity and respect.
Diversity, Equity and Inclusion Policy
At Hertzian, we are committed to fostering a diverse and inclusive workplace where every individual is valued and treated with dignity and respect. We believe that a diverse workforce is essential to driving innovation, creativity, and success, and we strive to create an environment where everyone has the opportunity to thrive. We are dedicated to promoting equality in all aspects of our business operations, including recruitment, training, development, and promotion. We aim to ensure that our policies, practices, and procedures are fair, transparent, and accessible to all, regardless of race, ethnicity, gender, age, sexual orientation, disability, religion, belief, or any other characteristic protected by law. We actively encourage an inclusive culture where people from all backgrounds feel welcome, supported, and empowered to contribute their unique perspectives. Our commitment to equality and diversity extends to both our employees and the communities we serve, and we will continuously work towards creating an environment where fairness and respect are at the heart of everything we do. We believe that by embracing and celebrating differences, we create a stronger, more dynamic, and more successful organization.
We are committed to promoting equal opportunities in employment and creating a workplace culture in which diversity and inclusion is valued and everyone is treated with dignity and respect. As part of our zero-tolerance approach to discrimination in any form, you and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics). We are also committed to providing equitable treatment to all those we deal with as an organisation, including customers and suppliers.
About this Policy
This policy sets out our approach to diversity, equity and inclusion. Our aim is to encourage and support diversity, equity and inclusion and actively promote a culture that values difference and eliminates discrimination in our workplace. It applies to all aspects of employment with us, including recruitment, pay, benefits and conditions, flexible working and leave, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.
This policy applies to all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers.
The Directors are responsible for this policy and will review it annually. This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.
Diversity and Inclusion Training
Managers will be given appropriate training on recognising and avoiding discrimination, harassment and victimisation, and promoting equality of opportunity and diversity in the areas of recruitment, development and promotion.
We will provide you with regular training to ensure that everyone is aware of and understands the contents of this policy and the Anti-harassment and Bullying Policy. Following the training, you will be required to confirm that you have read, understand and will comply with this policy and the Anti-harassment and Bullying Policy.
Discrimination
You must not unlawfully discriminate against or harass other people, including current and former staff, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts), and on work-related trips or events including social events.
The following forms of discrimination are prohibited under this policy and are unlawful:
- Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.
- Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.
- Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.
- Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment. This includes where someone mistakenly believes that the person victimised has done so.
- Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.
Recruitment and Selection
Recruitment, promotion, and other selection exercises, such as redundancy selection, will be conducted based on merit, against objective criteria that avoid discrimination. When recruiting or promoting, we will aim to take steps to improve the diversity of our workforce and provide equality of opportunity.
Shortlisting and interviewing should be done by more than one person where possible. Our recruitment procedures will be reviewed regularly to ensure that individuals are objectively assessed based on their relevant merits and abilities. Vacancies should generally be advertised to a diverse section of the labour market.
Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. Advertisements should include a short policy statement on equal opportunities and the employer’s commitment to diversity, equity, and inclusion in the workplace and state that a copy of this policy will be made available on request. Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic.
For example, applicants should not be asked whether they are pregnant or planning to have children. Job applicants should not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law. For example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check.
Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes. We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from Legal at Hertzian.
Disabilities
If you are disabled or become disabled, we encourage you to tell us about your condition so that we can consider what reasonable adjustments or support may be appropriate.
Part-time and Fixed-term Work
Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
Breaches of this Policy
We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination and victimisation may amount to gross misconduct resulting in dismissal.
If you believe that you have suffered harassment, bullying or discrimination, or witnessed it happening to someone else in the workplace, you can raise the matter through our Grievance Procedure. Complaints will be treated in confidence and investigated as appropriate.
There must be no victimisation or retaliation against staff who complain about or report discrimination. If you believe you have been victimised for making a complaint or report of discrimination, or have witnessed it happening to someone else in the workplace, you should raise this through our Grievance Procedure.
We encourage the reporting of all types of potential discrimination, as this assists us in ensuring that diversity, equity and inclusion principles are adhered to in the workplace. However, making a false allegation in bad faith, or that you know to be untrue, will be treated as misconduct and dealt with under our Disciplinary Procedure.
Contact Us
To contact us, please email legal@hertzian.co.uk
