Modern Slavery Act 2015 (“the Act”)

Introduction

Zenitech Group is committed to acting ethically and with integrity in all its business dealings and relationships. Modern slavery is a crime and a violation of fundamental human rights, and we have established systems and controls to help us to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Zenitech’s Business Structure

Zenitech delivers transformational technology by analysing our clients needs, and then creating and delivering the technology solutions. Our end-to-end technology solutions are designed by skilled technology employees across the globe. Zenitech has offices in Lithuania in both Vilinus and Kaunas We also have offices in Cluj-Napoca in Romania and Miskloc in Hungary. In addition, we have UK based employees who provide central services such as sales and marketing expertise.

Our Supply Chains

Our primary supply chain activity is the provision of technical services to customers. We recruit candidates to fulfill these assignments. We procure IT and office equipment, facilities and related services (such as cleaning, catering and similar office-related support services) for our offices across the globe.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business, and this is reflected in policies. We continue to review our supply chains and to consider the risk that modern slavery could arise. We believe that the nature of our business and supply chains, when combined with these factors, means our policies ensure that the risk of modern slavery in our own organisation is low.

We ensure that all our employees are treated in a fair and equal manner with dignity and respect and have in place policies which prohibit any form of discrimination, victimisation or harassment. We have a growing programme of employee engagement to ensure that the views and any concerns of our staff are heard by management and our Board of Directors. We carry out full checks on all applicants and ensure that they have a right to work in the location where we are recruiting them.

Our Review of Risk

We audit our organisation to establish that we are compliant with applicable minimum wage regulations and working hour restrictions across all jurisdictions in which we operate. We have also confirmed that we are compliant with overtime regulations in those jurisdictions which have them.

Our Due Diligence Processes

We continue to implement a process of due diligence on our existing key suppliers to ensure compliance our obligations under the Act. Where applicable suppliers are required to complete a Supplier Due Diligence Form which is submitted for assessment. These processes are intended to identify and assess potential risk areas in our supply chains and to mitigate that risk as far as it is reasonably possible to do so.

Training

We aim to promote a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, and we familiarise all staff with our policies on induction. Where appropriate, we will provide additional training on the risks of modern slavery to those of our staff who are engaged regularly with our supply chains.

Monitoring Effectiveness

Our compliance with our policies is monitored and implemented by our legal, governance and HR teams. We will review the effectiveness of our new policies and report regularly to our board of directors, when we will make recommendations on any additional steps which we believe will further mitigate the risk of modern slavery in our organisation and its supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes FDM Group’s slavery and human trafficking statement for the 12-month period ending 31 December 2022.