Modern Slavery Statement

Overview
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 (“the Act”) and applies to Bladeroom Holdings Limited and its principal operating companies Bladeroom Group Limited and ModuleCo Limited (together “Bladeroom”). It sets out the steps taken, is continuing to take and intends to take to ensure that modern slavery or human trafficking is not taking place within its business and supply chain. Bladeroom fully supports the objective of the Act, which requires businesses to set out what steps have been taken in the financial year to ensure modern slavery is not occurring in their supply chain and in their own organisation.
This statement refers to the financial year ending 31st March 2019.

Organisational Structure
Bladeroom is a privately-owned international provider of highly energy efficient, modular data centres and mission-critical, technically complex, modular facilities to the Healthcare and Pharmaceutical sectors. The business is controlled by a Board of Directors and employs over 70 people in the South West and Midlands.
Bladeroom has successfully delivered facilities to clients in the UK, Europe, Africa, Australia and the USA. We have established key partnerships and alliances with suppliers, providers and service partners – all chosen because they actively contribute to a key aspect of our operations. We develop long term relationships with these key partners and avoid making demands that might lead to them violating human rights.

Policies
Bladeroom acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Bladeroom understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
Bladeroom 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.
Business is conducted in an honest and ethical manner. 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 Bladeroom in any capacity.

Supply Chain Management
In order to fulfil its activities, the main supply chain partners of the Bladeroom are situated in the UK.
We are implementing a risk-based approach to identify, prevent, mitigate and account for how Bladeroom addresses threats of modern slavery and human trafficking. We are taking steps to assess the actual and potential human rights impacts by conducting due diligence on a sample of our direct suppliers. These suppliers have been asked to complete a survey intended to understand the risk of modern slavery in their supply chain and actions being taken to address this risk. The results of this survey will inform our engagement with suppliers in the financial year ending 31 March 2020.

Exposure to slavery and human trafficking
We have considered the risk of Bladeroom being exposed to slavery and human trafficking, taking into account:
• The highly skilled nature of roles and activities undertaken within Bladeroom, and the competencies required to perform them;
• The application of our policies, including whistleblowing and anti-bribery & corruption; and
• That our supply chain operations are substantially based in the UK.
As a result of the factors above and, as noted elsewhere in this statement, we deem the risk of slavery or human trafficking occurring within our business to be relatively limited.

Governance
Bladeroom shall take responsibility for this statement which will be reviewed and updated as appropriate.

This statement was signed by the Managing Director on 20th November 2019, on behalf of the Board of Directors.

William Thornton
Managing Director
20th November 2019

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