MODERN SLAVERY ACT STATEMENT
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes the slavery and human trafficking statement (“Modern Slavery Statement”) of Pavocat Group Ltd and its subsidiaries (or “Pavocat”).
The board and management of Pavocat Group has a zero-tolerance approach to modern slavery and are committed to ensuring that there is no modem slavery or human trafficking in any part of our business, including our supply chain.
Pavocat specialises in the fields of (1) counter-corruption and (2) the laws of conflict and human rights, in which it provides a full spectrum of services as well as practical training. The training is provided by the Pavocat Stellenbosch Academy, which is an academic unit within Stellenbosch University. Courses are accredited by the university’s Faculty of Law and/or the Faculty of Military Sciences. Pavocat Group is headquartered in central London and has subsidiary companies in the UK, European Union and South Africa.
Pavocat has the following measures in place to reduce the risk of modern slavery affecting its business and supply chain:
1. Policies & Procedures
1.1. Pavocat has a Code of Conduct which focuses on maintaining positive relationships with all counter-parties, including business partners, suppliers and the wider communities in which we work.
1.2. The policy promotes working within the laws and regulations of the countries in which we operate (including, by implication, those relating to forced/involuntary labour and human trafficking), promoting high ethical standards and a culture whereby people are empowered to report issues of concern. Business integrity is a key standard in the selection of partners, contractors and other organisations with which NEO Energy works. This policy is communicated to all employees and compliance with its requirements is a condition of employment with Pavocat.
1.3. Pavocat is committed to providing safe and healthy working conditions for its personnel and conducts its business as a responsible corporate citizen.
2. Supply Chain
2.1. We look to procure products and services from high quality and high integrity suppliers. We achieve this through a robust selection process and ongoing management of suppliers who fully comply with our safety, environmental and ethical standards.
3. Contractual Terms
3.1. Pavocat’s template contractual terms for contractors require the highest standards of business ethics, compliance with all applicable laws and commitment to health, safety and the protection of the environment and personnel.
4. Reporting Concerns
4.1. By encouraging a culture of openness within our organisation NEO Energy aims to prevent malpractice. We encourage all employees to raise issues which concern them at work through the Whistleblowing Policy which is made available to them.
5. Risk Assessment
5.1. Pavocat has undertaken an internal risk assessment to identify and assess potential risks in our supply chain relating to modern slavery and human trafficking. Pavocat does not operate in a sector which has particular risks associated with slavery and human trafficking but it may have to operate in jurisdictions where such risks may or are known to exist. To the extent risks have been identified, appropriate steps have been taken to mitigate and monitor such risks as outlined above.
5.2. Pavocat is committed to ensuring that there is no modem slavery or human trafficking in our supply chain or in any part of our business, and that the same high standards are applied by our business partners. Pavocat has a robust set of guidelines and policies in place that inform our work, and ensure we are considering the impact of our corporate behaviour as appropriate.
5.3. At the time of writing, Pavocat is not aware of any current or recent incidents, nor accusations of forced/involuntary labour or human trafficking in our operations or those of our business partners.