Document Ref: 14106-G-Modern Slavery Statement
Version 1.8 – Issue Date: 24 October 2024
Ark and any subsidiary companies are committed to operating with due respect for human rights and a desire to support ethical development through our business activities. We work with our supply chain to ensure that we comply with our obligations under the Modern Slavery Act 2015.
We are fully committed to implementing and enforcing effective systems and controls to ensure that modern slavery is not taking place anywhere in our supply chain.
We take and expect a zero-tolerance approach to modern slavery from all of our contractors, suppliers and other business partners, and have introduced contractual provisions to prohibit the use of forced, compulsory or trafficked labour.
We publish a statement each year, which sets out the steps we have taken to ensure that there is no slavery or human trafficking in any part of our business or supply chain.
Any incidences of modern slavery will be dealt with robustly and we will cooperate with the relevant authorities to ensure it is dealt with to the full extent of the law.
The Senior Leadership Team (SLT) have overall responsibility for ensuring this policy and its implementation comply with our legal and ethical obligations. Ark is committed to ensuring that all Ark employees receive the appropriate training to ensure that they are able to identify potential incidences of modern slavery in the content of this policy with the aim of stamping out such practices.
1.1 This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by Ark Data Centres Limited (“Ark”) any subsidiary companies such as Crown Hosting Data Centres Limited (CHDCL) as well as any entities within the wider Ark Group during the year ending 30 June 2024 to prevent modern slavery and human trafficking in its business and supply chain.
2.1 Ark seeks excellence in every aspect of its business and strives to ensure the highest standards of professionalism, integrity, and ethical business practice. We are committed to lawfully conducting our business and this includes engaging with our suppliers to ensure that they share our high standards.
2.2 We fully support the objective of the Modern Slavery Act of 2015, which requires businesses to set out what steps they have taken during the financial year to ensure that modern slavery is not occurring in their supply chains and their organisation.
3.1 Ark empowers businesses to work from anywhere in the world by designing and operating data centres that lead the market in social responsibility. Ark operates Data Centres predominately within the United Kingdom with one Data Centre site under construction in Europe, a list of our current locations can be found here.
3.2 Our pioneering facilities leverage 100% renewable energy, optimum security, high availability, and offer world-class sustainable scalability.
3.3 Every member of staff is responsible for reporting any instances of potential Modern Slavery activities they identify. The broader responsibility for assessing and responding to modern slavery governance risk to allocated to the management team. Additional detail on Ark and associated entities management team can be found here and here.
3.4 We have established several key partnerships and alliances, with suppliers, providers, and service partners, known collectively as our supplier – are all chosen because they actively support our operational activities. We foster long-term relationships with these key partners who share our principles and ethos and avoid making demands or requests that might lead to them violating human rights. These key partnerships include products such as the systems or infrastructure used within the provision of space and associated services within Ark’s data centres through to supporting personnel to provide specific expertise or functions.
4.1 We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or any part of our business. Our Modern Slavery Policy (14104-A-Modern Slavery) reflects our commitment to acting ethically and with integrity in all our business relationships in addition to implementing effective due diligence to ensure that modern slavery is not taking place anywhere in our supply chain.
4.2 We operate a Whistleblowing Policy (3046-A-Whistleblowing) so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
4.3 Our Health & Safety Policy (14021-A-Health & Safety) sets out Ark’s commitment and approach to providing and promoting a safe and healthy working environment.
4.6 Our Procurement Policy (5029-A-Procurement) outlines Ark’s approach to ensuring procurement activities comply with all relevant laws, directives and regulation and that Ark does not support sourcing where the minimum and (nationally or internationally) legally required standards are not applied.
4.7 These policies apply to all individuals working for or on behalf of Ark in any capacity.
5.1 To ensure that the wider Ark service offering is following the direction of the Modern Slavery Policy on aspects of Modern Slavery, Ark has placed a flow-down obligation on all suppliers of services and goods whereby the provisions of the Modern Slavery Act are a contractual obligation. This ensures that statements made by Ark are supported by relevant facts, information, and accounts from our supply chain so that Ark can be confident of child and forced labour use within our supply chains.
5.2 We have a adopted and utilise a risk-based approach to identify, prevent, mitigate, and account for how Ark addresses threats of modern slavery and human trafficking. We have taken steps to assess the actual and potential human rights impacts by conducting due diligence on a sample of our direct suppliers.
5.3 Our suppliers participate in a Modern Slavery Supplier Survey which enables Ark to understand the risk of modern slavery in their supply chain, the actions being taken to address this risk as well as any current events or matters that could give rise to potential risk.
5.4 We did not find any evidence of non-compliance throughout the evaluated supply chain against the Modern Slavery Act 2015.
5.5 The results of the survey were compared to the data from previous assessments to identify any trends. This analysis has enabled Ark to identify areas where the supply chain are performing well and if there are any opportunities for improvement. This output informs current decision making and influences our engagement with suppliers in the future.
5.6 As part of these activities, we also completed additional reviews of the statements published by our principal suppliers and partners. This exercise has provided Ark with further assurances that our supply chain is taking effective action to meet the requirements of the Modern Slavery Act 2015.
6.1 High levels of awareness across Ark will be key in the company’s success in ensuring that modern slavery is targeted more effectively and persistently.
6.2 Ark’s Modern Slavery Policy (14104-A-Modern Slavery) has been communicated to all staff and reinforces the Leadership Team’s commitment to ensuring that modern slavery is not taking place anywhere in our operations and supply chain.
6.3 All new starters to Ark undertake a Compliance Induction which sets out Ark’s commitment to tackling modern slavery, how to spot potential instances of modern slavery and what employees should do if they identify a potential case of modern slavery. Following the session, all new starters have to provide confirmation that they have read and understood Ark’s Modern Slavery Policy (14104-A-Modern Slavery) and this statement, with any associated trends or issues reviewed at Ark’s Management reviews.
6.4 Additional information regarding modern slavery is available to all staff on Ark’s intranet. The purpose of this resource is to provide staff with a more detailed understanding of modern slavery and help individuals identify signs of modern slavery. It also includes information on whom staff should contact should they have any concerns.
6.5 Ark is looking to implement periodic supplementary staff briefings in addition to the existing training and awareness provided with the first session scheduled for the end of October 2024. This is to ensure the organisation remains informed of current developments on this topic and we adapt to any emerging risk relevant to Ark or out supply chain.
6.6 Staff are encouraged to report any concerns or suspicions regarding the presence of modern slavery.
7.1 We have considered the risk of Ark being exposed to slavery and human trafficking, taking into consideration: 7.1.1 The highly-skilled nature of roles and activities undertaken within Ark, and the competencies required to perform these, reduces our exposure to modern slavery,
7.1.2 The application of our policies, including but not limited to whistleblowing, Code of Conduct, anti-bribery & corruption, Gift and Hospitality,
7.1.3 The results of the FY2024 Modern Slavery Supplier Survey which found no evidence of non-compliance with the Modern Slavery Act 2015,
7.1.4 The limited supply chain operations in countries with a high prevalence of modern slavery, informed by the Global Slavery Index,
7.1.5 The ongoing training and awareness resources made available to staff.
7.2 As a result of the factors above and noted elsewhere within this statement, we deem the risk of slavery or human trafficking occurring within our business and direct supply chain remains low.
7.2. As a result of the factors above and noted elsewhere within this statement, we deem the risk of slavery or human trafficking occurring within our business and direct supply chain to be low.
8.1 Ark shall take responsibility for this statement which will be reviewed and updated as appropriate.
8.2 This statement was approved by the Management Team on the 14th October 2024 and has been signed by the Compliance Director, on behalf of the Senior Leadership Team.
Louise Methven
Compliance Director
Ark Data Centres Limited & Crown Hosting Data Centres Limited
14 October 2024
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