Modern Slavery Act

For Financial Year 2020/21


The Modern Slavery Act 2015 came in to force on the 29th of October 2015, with the aim of reducing and preventing modern slavery and human trafficking. All commercial organisations operating in the UK, with a turnover of £36 million or greater are required to publish, or make available, a Modern Slavery and Human Trafficking Statement. Every organisation’s Modern Slavery and Human Trafficking Statement must be reviewed, updated, and re-published each financial year. This statement sets out Sync’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.


This statement relates to actions and activities during the financial year (1 January 2020 to 31 December 2020). As part of it’s operations to provide ICT hardware and services to consumers, businesses, educational establishments, charities, and public sector bodies, Sync recognises that it has a responsibility to take a robust approach to slavery and human trafficking. Sync is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure

GBM Digital Technologies LTD is a wholly owned subsidiary of GBM Digital Technology Holdings LTD.

GBM Digital Technologies LTD [GBM] are an ICT hardware and services provider, providing technology-oriented products and services to consumers, businesses, educational establishments, charities, and public sector bodies.

GBM Digital Technologies LTD also trade as Sync, and Sync Store. Sync and Sync Store were created for the primary purposes of selling goods and services to consumers.

GBM operate in the UK only, and supply within the UK and EU only.

Supply Chains

Our supply chains are non-complex, and typically fall in to one of two models:
The responsibility for GBM’s anti-slavery initiatives is as follows:

  • Purchasing directly from the manufacturer
  • Purchasing from a distributor, who is authorised to distribute goods and services on behalf of the manufacturer


Policies – Board of Directors

Risk Assessments – Procurement regarding supply, HR regarding employment

Investigations & Due Diligence – Board of Directors

Training – Board of Directors

Relevant policies

Sync operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy – Sync encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of Sync. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Sync’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

Employee Code of Conduct – Sync’s code makes clear to employees the actions and behaviour expected of them when representing Sync. Sync strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

Supplier Code of Conduct – In 2018, GBM started to introduce a Supplier code of conduct – further works will continue through 2020. The code of conduct outlines GBM’s commitment to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to certify and/or demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Under this commitment, GBM may work with suppliers as necessary to ensure that they meet the standards of the code and improve their worker’s working conditions. Serious violations of the Supplier Code of Conduct, however may lead to sanctions against the supplier, and ultimately, termination of the business relationship. We will continue to evaluate new supply chain partners through the year.

We will also run compliance checks against the suppliers on CRM systems to ensure that we are indeed capturing this data from all suppliers.

Recruitment policy

In 2019, GBM continued working toward a more robust Recruitment policy, to include:

  • conducting ‘eligibility to work in the UK’ checks for all employees to safeguard against human trafficking or individuals being forced to work against their will
  • procedures to ensure that GBM only utilises reputable employment agencies to source labour, and always verifies the practices of any new agency it is using before accepting workers from them

Inline with this commitment, GBM have explored a number of new recruitment channels through 2018 and 2019, including agency, and digital-lead routes. We will continue to develop our recruitment policy through 2020.

Due diligence

In 2019, GBM continued its work in building out a processes to undertake enhanced levels of due diligence when considering taking on new suppliers, and regularly review its existing suppliers. GBM’s due diligence and reviews have included:

  • mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified; and
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship

GBM will continue working to evaluate its suppliers across 2020, with a view to assessing and mitigating risk in the supply chain.

Assessing risk

In 2019, GBM continued its work in looking to introduce new measures to assess and manage the risk of activity carried out across our supply chain. This will form part of our supply chain vetting process, and will take key risk areas in to account, including those associated with:

  • Country
  • Sector
  • Transactions
  • Business partnerships

GBM are committed to continuing this work in to 2020.

Performance indicators

GBM has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, GBM have:

  • developed a system for supply chain verification, whereby GBM can evaluate its suppliers.
  • In 2020, our aim is continue progressing our work from 2019, and to move to a system where we can fully vet suppliers before they come on-board with us.

We will monitor the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain. The key metric being that no reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.


Our policies, (i.e. Whistleblowing, and Employee Code of Conduct) are currently made available to all employees via the staff handbook. We had hoped to expand on this in 2019, by making training available to all of it’s employees, with an aim to both:

This has now been set a target completion date in 2020.

  • raise awareness, and educate our employees about Modern Slavery and Human Trafficking, and
  • inform them about our internal policies for prevention.

Board approval

This statement has been approved by GBM’s board of directors, who will review and update it annually.