Modern Slavery Policy
ManagingDigital is owned and operated by Ajar Group Limited (AGL).
AGL is committed to combating slavery and human trafficking in its business and supply chain, and to acting ethically and with integrity in its business relationships. This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015. It constitutes AGL’s slavery and human trafficking statement for the financial year ended 31 October 2021.
Ajar Group Limited incorporated and registered in England and Wales with company number 10432472 whose registered office is at 37 Great Pulteney Street, Bath BA2 4DA, United Kingdom, trading as CC&C Europe. is the European representative of CC and C Solutions Pty LTD, a global Enterprise Architecture consultancy and training company. Websites operated by Ajar Group include managingdigital.com, danwarfield.io, ccceurope.com, jnwarfield.com and ajarpublishing.com.
As part of CC&C we are a member of The Open Group and the BIAN global standards bodies and abide by their compliance requirements. With fewer than 50 staff, the CC&C group is based primarily in the United Kingdom, United States, Singapore, India and Australia. Our staff are either directly employed by the relevant CC&C corporate entity or are independent professionals contracted for specific professional services. This policy also describe AGL staff, associates and subcontractors who are engaged for purposes unrelated to the CC&C Europe business.
Our staff are primarily senior business or technology professionals such as Enterprise Architects, university lecturers, software design consultants, IT strategists, etc. None are in a category generally seen to be vulnerable to modern slavery in the UK or elsewhere.
All contractors are required to comply with all applicable employment law and money laundering, tax and other relevant regulations.
Our Supply Chain
AGL and CC&C use a small range of reputable suppliers who either supply goods for resale or provide professional services and support for our operations. We have no suppliers based in high-risk countries, and/or manufacturing goods for resale.
Our suppliers include organizations such as Vodafone, Cisco, Zoom, InMotion Hosting, Van Haren Publishing B.V., Van Haren Learning B.V, BiZZdesign, Dell and The Open Group, and licensed professionals such as solicitors and chartered accountants. We regard all our current suppliers as very low risk for modern slavery and thus do not actively vet them or require compliance statements
AGL and CC&C do not conduct formal internal training with regard to modern slavery. This may change if our staffing or supply chain profile changes, as described below.
Due Diligence and Compliance
Our policy on compliance matters is always to take competent professional advice to ensure awareness of potential requirements, and implementation of correct policy based on actual requirements.
The turnover of AGL is too small for a statement such as this to be mandatory. However, we have created and published this policy in order to meet the compliance requirements of our partners as well as to be clear about our own position, with the participation of professional advice from the UK Institute of Directors and our own solicitors.
We currently view all our staff and suppliers as low risk for modern slavery. We are conscious that this may change and our policy therefore is that before contracting with suppliers based in high-risk countries and/or manufacturing goods for resale by AGL, or employing or contracting for local staff in categories seen to be vulnerable to modern slavery, AGL will seek and take professional advice to ensure that any such action is done in accordance with such UK and other laws and regulations as may be in force at that time, and with industry best practice.
This may include (for example):
- Appropriate contract language
- Vetting and record checking for individuals
- Enhanced policy statements including procurement policies
We will investigate any allegation that a supplier has breached a contractual or statutory obligation to comply with anti-slavery requirements, and if this is in fact the case we will terminate the contract and report the breach to relevant authorities.
This statement has been approved by the Directors of Ajar Group Limited.
(signed) Daniel Warfield, Managing Director