Modern Slavery

Company Policy Document

Definition of Slavery

Slavery is where ownership is exercised over a person; servitude involves the obligation to provide services imposed by coercion; forced or compulsory labour involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself voluntarily; human trafficking concerns arranging or facilitating the travel of another with a view to exploiting them.

The Company will ensure that it will comply with the Modern Slavery Act 2015 and is putting strict measures in place to ensure that no slavery is part of any of our business operations that includes our supply chains, goods, and services.

Risks of Modern Slavery within our Business

Total Computer Networks Ltd (TCN) has a risk-based methodology in place to ensure its suppliers comply with the Act. Given the nature and locations of our business, we consider ourselves to be at low risk of the potential for slavery or human trafficking. Whilst we also believe that our business model and strategy is unlikely to create material risks of slavery and human trafficking, we have a number of procedures in place which we consider to be effective to prevent modern slavery from occurring in our business or supply chains.

Supply Chain Selection, Measures & Controls

We acknowledge our responsibilities under the Act, and we are committed to preventing slavery and human trafficking within our businesses as well as our supply chains. We understand that this requires an ongoing review of our internal practices and continual due diligence of our supply chains.

TCN have a strict process of supplier selection and ongoing review. As reseller of goods and services and not a manufacturer, we expect our suppliers to self-audit and monitor their supply chains and provide us with that evidence as part of their onboarding.

As part of our zero-tolerance policy, we will not enter into business, and will discontinue any current business, with any other organisation which knowingly supports or is found to involve itself in slavery, servitude or forced or compulsory labour. Our policy reflects our broader commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place within our business or supply chains.

We acknowledge our responsibilities under the Act, and we are committed to preventing slavery and human trafficking within our businesses as well as our supply chains. We understand that this requires an ongoing review of our internal practices and continual due diligence of our supply chains.

An overview of the Company’s organisational structure, its business and supply chains are as follows:

  • Trading with Public and Private Sector business to business customers
  • Organisation structure is made up of Directors and Managers from Total Computers and TotalServices trading under Total Computer Networks Ltd.
  • Total Computer Networks sources its goods from tier one authorised distributors.
  • Supply chain involves, Manufacturer, Vendor, Total Computers, Business customer.
  • Relationships are built and maintained with vendor relation and good working relations managed by a team of people within Total Computers.

The supplier risk management process is as follows:

  • Review each supplier and identify what services they provide and consider the impact they could have on information security.
  • Evaluate each supplier by conducting a risk assessment. This enables us to categorise suppliers into a rating. High, medium & low risk.
  • The level of assurance is dependent on the level of risk.
  • For those suppliers categorised as medium or high risk we obtain suitable safeguards asappropriate.
  • Where required Total Computers will collaborate with high-risk suppliers to develop a specificaction plan to further mitigate the risk.
  • Risk register is updated.
  • Off boarding – if the risk is deemed too high, Total Computers reserves the right to no longertrade with the high-risk supplier.

The Company embraces socially responsible trading as part of SEDEX and wherever possible we use Fairtrade ingredients. We audit our suppliers to ensure their production sites meet our very high standards and we worth with customers to ensure optimum environmental friendliness. This will also extend to their employment practices and procedures to ensure that no slavery or human trafficking exists in their business.

The Company has a Supplier Code of Conduct that states Total Computers is committed to ethical business practices and we hold our suppliers to the same high standards. It is Total Computers policy to comply with all applicable laws and regulations of the countries and regions in which we operate and to conduct our business activities in an honest and ethical manner. The Total Computers Code of Conduct declares that Total Computers expects its suppliers to uphold the policies of Total Computers concerning compliance with all applicable law, respect for human rights, environmental conservation and the safety of products and services.

Our Ethical Principles

We believe that behaving ethically is an essential part of how we do business. Our five principles of ethical business conduct when dealing with our clients, customers, suppliers, employees, and all others with whom we work or whom we encounter while representing us are:

  • Trust and Integrity: Our business prides itself on our reputation, and our clients and customers trust in the services that we provide. Where we make a commitment, we believe that it is important that this is delivered.
  • Accountability: We believe that we are all personally answerable for our conduct and actions.
  • Compliance: We will comply with all national and international laws and regulations that relateto how we operate as a business. We also aim to have processes that are seen as bestpractice that go beyond regulatory compliance.
  • Open and Honest: We will answer all questions in a frank and straightforward manner. We willnot attempt to provide misleading information.
  • Dignity and Respect: We will value each individual and treat them with dignity and respect.


We will strive to ensure that no labour provided to us in the provision of our services is obtained by means of slavery or human trafficking. As an equal opportunities’ employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our employees. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion. We adhere to all relevant employment legislation in the United Kingdom.

Any recruitment agencies we use we will ensure that they have strict compliance to this Act and require confirmation from them that no agency worker is being exploited as part of any slavery or human trafficking. The Company has a Recruitment and Selection Policy that ensures compliance with equal opportunities and states that recruitment agencies used come from the Company’s Preferred Supplier Listing. 

If it is established that any employee has committed an offence as follows, they will be subject to the Company’s Disciplinary Process:

  • the person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or
  • the person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour. 

If a supplier is found to have committed the above then the Company will cease trading with them immediately and the Company will report them to the relevant authorities, such that could include, HMRC, Health and Safety Executive, Modern Slavery Helpline, the Police, and the Home Office.

The Company will provide suitable training for all employees to ensure that they are aware of this Statement and can be vigilant in identifying and reporting any concerns they have. The Company has a Corporate Social Responsibility Policy, and a Business Ethics and Integrity and Code of Conduct policies for its employees to comply with.

This statement is made pursuant to section 54(1) of the Modern slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year 2023 and is approved by the Board of Directors of Total Computer Networks Limited. 

Kevin Goodall,

Managing Director

Date: 14/02/2024