Modern Slavery Statement

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Introduction

Derivco Holdings Limited, together with its wholly owned subsidiaries (the “Group”), is committed to promoting fair and ethical practices which includes preventing slavery, servitude, forced or compulsory labour and human trafficking (“Modern Slavery”). This statement is designed to satisfy the requirements of Section 54 of the Modern Slavery Act 2015 (the “Act”) and sets out the steps the Group has taken during the financial year ended 31 December 2023 to reduce the risk of Modern Slavery occurring in its businesses or supply chains.

Business

The Group provides software development, IT support & maintenance services, and ancillary services to its customers. The Group also licenses online sports and gaming platform systems across several online gaming markets. 

Structure

The Group includes the following wholly owned subsidiaries:

  • Derivco Systems SL (Spain)
  • Derivco Australia (Pty) Ltd (Australia)
  • Derivco Sweden AB (Sweden)
  • Derivco Isle of Man Limited (Isle of Man)
  • Derivco Ipswich Limited (UK)
  • Derivco UK Limited
  • Derivco USA
  • Derivco Malta Limited (Malta)
  • Chasefield Investments (Pty) Ltd, including its wholly owned subsidiary Derivco (Pty) Ltd (South Africa)

Supply Chains

The Group’s supply chains comprise suppliers which provide goods and services including, but not limited to, IT hardware, infrastructure, software, consultancy, professional services, recruitment, travel, property, and civil works.

The Group are implementing risk-assessment measures to reduce Modern Slavery practices within its business and its supply chains and implementing policies to deal with such practices if identified or if classified as being at higher risk of such practices. Whilst it is acknowledged that risk factors exist across all global supply chains and sectors, it is believed that the Group’s relative exposure to Modern Slavery is low given the nature of its business as a software developer and provider of services in the highly regulated online gaming industry. The Group primarily procures goods and services from established organisations in relatively low-risk areas as outlined above. Further, the Group operates in jurisdictions which do not have a high prevalence of Modern Slavery.

Policies and Due Diligence Processes

The Group is implementing necessary steps to better identify the risk of Modern Slavery occurring within its supply chain. The Group’s Procurement Policy has been updated to require that due diligence checks are performed on any supplier prior to engagement. 

The Group’s updated Procurement Policy is being implemented through a process to assess potential suppliers, before onboarding. The assessment includes the nature and extent the supplier is exposed to the risk of Modern Slavery. As part of the onboarding, potential suppliers will be actively encouraged to sign the Group Supplier Code of Conduct. The Supplier Code of Conduct requires the supplier to confirm, by signing and dating the declaration that they are not engaging in Modern Slavery and requires them to actively monitor and prevent Modern Slavery in their own supply chain. An exercise is underway to perform these due diligence checks for existing suppliers so that a complete database of Group suppliers is maintained. If the Group discovers that a supplier is in any way involved in Modern Slavery, any arrangement with such entity would be immediately under review. 

Recruitment Practices

A Group HR Recruitment Policy is being updated to embed and align the principles and ethical standards of human resource recruitment and supply across the Group. The Group has robust recruitment processes that ensure appropriate checks on new recruits are carried out prior to the relevant staff member commencing employment. Employees within the Group are protected by localised HR policies which uphold the Group’s commitment to a high standard of ethics and integrity within its business.

The Group maintains a whistleblowing mechanism which allows individuals within the Group to report any suspicion that relates to a potential legal breach or wrongdoing such as possible fraud, crime, danger, or failure to comply with any legal obligation. Employees who are aware of, or suspect, Modern Slavery would be able to report such conduct through this channel.

Assessment of Risk 

The Risk Management Framework includes assessment of risks related to procurement, people, and compliance. This would include assessing the various controls implemented to reduce the risk of Modern Slavery. Internal audits will be conducted at regular frequencies to assess the effectiveness of the measures the Group has put in place.  

Training and Awareness 

Training is fundamental in raising awareness of Modern Slavery issues. The Group has identified relevant training which is intended to provide all our employees with an understanding of Modern Slavery and our obligations under the Act. As a Group, we seek to educate and upskill our employees.

Commitment

The Group reiterates its ongoing commitment to the Act and its underlying principles. Responsibility for ensuring and monitoring adherence to this statement rests with all employees. 

This statement will be reviewed annually and updated as required. The statement has also been reviewed by key stakeholders, senior management and has ultimately been approved by the Group’s Directors.

Quraish Behari 
CEO of the Derivco Holdings Limited Group of Companies

21 February 2024