Modern Slavery Act 2015
(“the Act”)

Introduction

This statement is made pursuant to Section 54(1) of the UK Modern Slavery Act 2015 and outlines the steps that the Zenitech Group has taken during the financial year ending 31 December 2024 to act ethically and with integrity in all its business dealings. 

Modern slavery and human trafficking are crimes and violations of our fundamental human rights, and we have established systems and controls to help us ensure a zero-tolerance approach to modern slavery and human trafficking in our business and supply chains.

Zenitech’s Business Structure

Zenitech is a global business specialising in the delivery of transformational technology by analysing our clients needs, and then building and delivering creative technology solutions. Our end-to-end technology solutions are designed by skilled technology employees across our operating locations.

We are headquartered in the UK from where we provide central services, such as sales, marketing and business support, with regional hubs in Lithuania (Vilinus and Kaunas), Romania (Cluj-Napoca) and Hungary (Budapest) focused on delivering technology solutions and R&D.

Our Supply Chains

Our supply chain activity is primarily the provision of technical services to our customers. We recruit candidates locally in each of our operating locations to fulfill these assignments and for our own business support services. 

We procure IT and office equipment, facilities (such as cleaning)  and related professional services (such as legal and audit) in each of our operating locations.

We recognise the potential risks associated with these diverse supply chains.

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 have implemented robust policies to combat this, including:

• Modern Slavery Policy – outline our commitment to preventing slavery and human trafficking
• Supplier Code of Conduct – set expectations for ethical practices amongst our suppliers
• Employee Concern (Whistleblowing) Policy – provides a confidential channel for reporting concerns

These policies are reviewed annually and are accessible to all employees and suppliers.

We continue to review our supply chains and to consider the risks where modern slavery could arise. We believe that the nature of our business and supply chains, means 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 are also 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 with 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 or talent acquisition processes.

Monitoring Effectiveness

Compliance with our policies, implemented by our Operational Excellence and People teams, is monitored by our Senior Leadership team. We review the effectiveness of our policies and report regularly to our board of directors, when we 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 2024.