This statement is made on behalf of Protocol Internet Technology Limited t/a Hosting Ireland pursuant to section 54(1) of the (UK) Modern Slavery Act 2015 (the "Act") and constitutes our slavery and human trafficking statement.
Hosting Ireland is registered in Ireland, is part of the Register group and has offices in Waterford. We have approximately 11 people in our office. We are an Internet Service Provider for the private sector.
Although the likelihood of an incidence of modern slavery in our business or our supply chains is low, we work to the highest ethical and professional standards and value transparency and accountability in all our dealings. We have a zero-tolerance approach to slavery and human trafficking and expect the same high standards from those we work with.
We have put in place a Modern Slavery Policy which is supported by other internal policies and HR processes such as our Whistleblowing Policy and Disciplinary Rules and Procedure.
The Directors are ultimately responsible for compliance internally and in our supplier relationships.
Supplier Due Diligence
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
Back in 2019 we decided to expand our Compliance programme to include due diligence checks on all existing suppliers and adding steps to our supplier on-boarding procedure(s). These checks were designed to include identifying those in our supply chain that adhered to the Modern Slavery Act 2015 by providing its customers with a statement of compliance in addition to ongoing checks to ensure compliance with data privacy and Critical National Infrastructure legislation and regulation.
In early 2020 we took a big step in launching a revised Supplier Management Policy that we felt supported and catered for all our interested parties, be it legislation or our customers. The process started by ensuring we had identified all suppliers and noted where we believed a supplier was critical to our business, be it a supply of core technologies we relied upon or processors of personal data, both areas required ongoing management and review.
After launching our revised Supplier Management Policy, the pandemic arrived impacting what ‘normal’ looked like for all residents in the UK, and worldwide. The ‘new normal’ had arrived and fortunately we had started to digitize our supplier records; we had a Supplier Management Log that recorded key data to enable us to continue to identify suppliers that were required to provide assurance of protecting their supply chain from modern slavery and human trafficking, identify where we had suppliers critical to our infrastructure or processed personal data. This meant we could continue to prepare for Brexit and ensure our new Supplier Management Policy would still be effective.
We still have work to do in 2021 digitising records that are stored in hardcopy at our head office, but we will continue to ensure that our suppliers meet the standards expected of all interested parties. We will continue to complete our internal review of suppliers, ensuring ongoing compliance with the Modern Slavery Act 2015 and any legislation changed by Brexit.
We will ensure any new relationships engaged complete the required due diligence levels we have introduced even in the challenging times placed upon us by the pandemic, meeting the high standards we hold ourselves to.
Any supplier that should adhere to the Modern Slavery Act 2015 but falls short of evidencing the requirements of the Act will be reviewed on a per case basis. Where compliance to the Act cannot be verified through our due diligence checks, and the supplier has advised a statement will not be made available, a new supplier(s) will be identified.