Modern Slavery Act

For Financial Year 2021/22


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. 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

Sync is a trading name of GBM Digital Technologies LTD.

GBM Digital Technologies LTD (company reg: 02719704) is a wholly owned subsidiary of GBM Digital Technologies Holdings LTD (company reg: 07355195), which in turn is a subsidiary of GBM Digital Technologies Group LTD (company reg: 12470566).

Sync is an ICT hardware and software reseller, and services provider. Sync provides technology-oriented products and services to consumers, businesses, educational establishments, charities, and public sector bodies.

Sync 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:

  • 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 and Directors regarding supply, HR and Directors 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 – Sync has started works to introduce a Supplier code of conduct. The code of conduct outlines Sync’s commitment to ensuring that its suppliers adhere to the highest standard 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, Sync 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. It was initially anticipated that works for this would be completed by the end of 2020, however this timeline was altered by the pandemic. Further works however will now continue through 2021.

Recruitment policy

Last year, Sync continued working toward a more robust Recruitment policy, to include:

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

Inline with this commitment, Sync have explored a number of new recruitment channels, including agency, and digital-lead routes. We will continue to develop our recruitment policy through 2021.

Due diligence

Over the last year, Sync 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, including:

  • 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

Whilst progress was slowed during the pandemic, Sync will continue working towards a more robust system, with a view to better assessing and mitigating risk in the supply chain.

Assessing risk

Sync is committed to enhancing existing measures, and introducing new measures to assess and manage the risk of activity carried out across its 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

Whilst progress was slowed during the pandemic, Sync will continue working towards a more robust system.

Performance indicators

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

  • made progress in the development of its systems to better handle supplier vetting
  • made changes to its recruitment process, utilising a centralised, reputable, and accessible platform for recruitment

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, our suppliers, 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 have also made a raft of content available to all employees (including training and video resources) utilising a premium subscription service, with an aim to both:

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

Board approval

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