Corporate Information


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Modern Slavery Act

Broadlight Global Ltd recognises that all organisations have an obligation to prevent slavery and human trafficking. Modern Slavery is an international crime affecting millions of people across the globe. It is an unacceptable practice involving people regardless of age, gender or ethnicity in developed (including the UK) as well as developing countries.

Within the UK, victims include people trafficked from overseas, or vulnerable people from the UK, who are forced to work illegally or against their will. As a services organisation where most of our workers are highly skilled and directly employed by our organisation, we consider the risk of modern slavery within our own organisation to be low. However, in order to operate efficiently and provide reliable services for our clients, we work with third parties, such as suppliers and contractors.

We recognise that removing modern slavery entirely from the supply chain presents challenges for many businesses such as Broadlight Global Ltd. The purpose of this statement is to satisfy part 6 of the Modern Slavery Act and to provide an update on our commitment to ensuring that our supply chains are free from slavery and human trafficking.

1. Organisation's Structure.
We are a next generation IT service company delivering business-critical strategic IT projects in the Information Technology and Services sector. Broadlight Global was founded in 2019.
Our supply chains include:
- Suppliers of IT equipment, software and services
- Professional services from lawyers, consultants, accountant
- Office cleaning and other office management services
- Marketing and other PR services
- Print and promotional material production
- Training organisations and venues.

2. Our Policies Relating to 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. Our Modern Slavery Act Policy reflects our commitment to acting ethically and with integrity in all our business relationships and through contractual terms we ensure that our suppliers are uphold to the same obligations and high standards so that slavery and human trafficking is not taking place anywhere in our supply chains.

This Anti-Slavery Statement and its practical effectiveness is reinforced by several existing and aligned Broadlight Global Ltd training information and policies, which include:

- Code of Conduct in which we provide the general foundation for how we conduct our business. It declares that board members and employees are obliged to comply with both applicable laws and regulations in the performance of their duties, and in accordance with good business practice, values and ethical guidelines when carrying out their work.
- Anti-bribery and anti-corruption policy to prevent bribery and corruption as well as ensuring compliance with national and international rules. We do not tolerate any bribery or corruption and we condemn it in all forms and we are committed to doing business in compliance with the policy and with integrity.
- Whistle-blower system in which employees, members of the Executive Board and Board of Directors, auditors, lawyers, suppliers and other business partners of the company can report serious offences or suspected serious offences. Reports may be submitted anonymously, and they are investigated by an external law firm.
- Our core values and ethical guidelines that make us a people-oriented workplace with strongly rooted human rights approach. Our expectation of being an inclusive and equality supporting organisation is guided by the United Nations' Declaration of Human Rights. Through our Code of Conduct training, policies and engagement with our employees, we regularly cover key topics of importance to the company and our employees, such as non-discrimination and protection against harassment.
- Through our Code of Conduct and related anti-corruption activities, we support the UN Global Compact anti-corruption tenth principle.

3. Due Diligence Process in Relation to Slavery and Human Trafficking.
Broadlight Global Ltd is committed to responsible supply chain management and its objective is to com ply with applicable laws and regulations and strive for best practice with regard to responsible supply chain management. Broadlight Global Ltd does not tolerate slavery and human trafficking and will not knowingly engage in, or deal or partner with any suppliers who engage in slavery or human trafficking. Broadlight Global Ltd employees are aware of the company's strong stance against slavery and human trafficking.

Broadlight Global Ltd has assessed the risk of slavery and human trafficking in its UK business and the assessment has revealed the risk of modern slavery in our own organisation to below. Our skilled and agile employees have greater control over their careers,and this significantly reduces the risk of modern slavery. We have a range of employment policies that protect and enhance our employee's experience at work. In compliance with English law, our recruitment team s conduct a right to work check on all new joiners. External resourcing is a potential risk area for Broadlight Global Ltd, although the highly skilled, specialist contractors we engage from time to time are at low risk of modern slavery offences.We consider the biggest risk of modern slavery to be outside our organisation.

Our risk assessment has revealed that the highest potential exposure to slavery and forced labour is likely to be in the following areas:
1. Supply chain - Suppliers of IT equipment, software and services.
2. Maintenance of our buildings - carried out by construction and property maintenance third parties.

Broadlight Global Ltd is committed to ensuring that its suppliers adhere to the highest standards of ethics. Antislavery obligations are included in our contracts with suppliers and they are required to confirm that no part of their business operations contradicts these requirements. Any serious violation may lead to termination of the business relationship.

As part of our commitment to identify and eradicate slavery and human trafficking from within our organisation and from those businesses with which we interact, over the past 12 months we have:
- Continued to ensure that our values and ethics are embedded across our business, in the way we interact with our clients, our employees and our suppliers.
- Continued to encourage the reporting of concerns and the protection of whistle-blowers.
- Rolled out our Code of Conduct to all new joiners to the company.
- Begun to build long-standing relationships with suppliers and to make clear our expectations of ethical business behaviour from them.

In 2022 we will:
- Review our supplier engagement processes by the end of our 2023 financial year to ensure continued compliance.
- Roll out our anti-slavery policy as part of staff training to raise awareness of modern slavery across our employee population.

4. Our Effectiveness in Combating Slavery and Human Trafficking
In order to assess the effectiveness of the measures we have taken we will continue to review the following key performance indicators:
- The number and nature of incidents reported via our whistle-blowing system.
- The number and nature of major and minor non-compliances reported to the Human Resources.
- The number and nature of incidents reported through our internal incident reporting mechanisms in relation to our suppliers.
In 2021 Broadlight Global Ltd:
- Received no reports of breaches through the whistle-blowing system.
- Has had to take no remedial actions in relation to modern slavery or human trafficking.
- Has received no notifications of violation of the supplier code of conduct by any of our existing suppliers.

Further improvements are being made to our processes and procedures in the coming 12 months to improve Broadlight Global Ltd policies relating to modern slavery and to better understand the Broadlight Global Ltd global supply chain and the modern slavery risks we are exposed to. This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Broadlight Global Ltd slavery and human trafficking statement for 2021.Transparency statement was reviewed and approved by Board of Directors for Broadlight Global Ltd on 02 November 2021.

Signed for and on behalf of Broadlight Global Ltd
Alex Higgins, Director of Broadlight Global Ltd

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Diversity and Inclusion

Our Diversity and Inclusion Policy is led by Steven O’Keefe who was previously Diversity Champion as an onsite talent acquisition lead at Mercer, part of the Marsh and Mclennan group.

Through his experience we have implemented the following practices across our business:
-Ensured continual training regarding unconscious bias.
-Developed key values in our business of Trust, Partnership, Energy and Innovation which are independent of any specific gender, religion, race etc. All our staff embody these values bias free.
-Held a quarterly diversion and inclusion review with all of the team to ensure we are meeting our key values.
-Worked with the Brighton LGBTQ+ community as part of our meetup series, ensuring we bring all our rich culture together.
-Had regular discussions with our employees to ensure that no form of bullying or discrimination is occurring within the business and that our working system, disability, age or any other variable about a person is non-discriminatory. To this end we have a committee in place which regularly meets and where all of our employees have a safe space to discuss anything they wish to raise.

At Broadlight Global Ltd, diversity and inclusion is central to our work with candidates and clients. We want to work with great people from every walk of life and to create an inclusive work environment where all our employees feel valued, respected and nurtured.

Inclusion and diversity go beyond race, gender, sexual orientation, and disability. It can also be based on the way people communicate or think or their social-economic background. We look at diversity and inclusion overall and constantly strive to locate and remove any unconscious bias.

We are fully committed to ensuring that we are in full compliance with all relevant laws and guidelines on inclusion and diversity. We extend our experiences also with our clients in order to share best practice and grow each other’s knowledge and ability in this area.

As a Brighton & Hove based business we strive to replicate the liberal and inclusive nature of the City and constantly shine a light on ourselves through our Diversity Champion Steven O'Keefe’s knowledge.

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Climate Emergency Declaration

Broadlight Global declared a climate emergency in December 2019 and agreed to update it in December 2021. This page provides the updated declaration. 

Broadlight Global will therefore commit to:

- Making our own activities net-zero carbon by 2030, both production and consumption;
- Achieving 100% clean energy across the companies full range of functions by 2030;
- Ensuring that all strategic decisions, budget formulation and planning policy is put in place to ensure protection of the environment and achievement of net-zero carbon by 2030.
- Influencing and inspiring our partners across the UK towards sound environment and climate goals.
- Calling on the UK Government to provide the powers and financial resources required to address the emergency.
- Working with The Carbon Trust to promote and drive corporate sustainability across the UK, helping to reduce climate impact and transition to a low carbon economy.
- To the global response to climate change through collective action, innovation leadership and influence.
- Investing in new technologies that offer sustainable solutions and business models that enable the conditions for change and positively transform by scaling that works.
- Constantly measuring and analysing Broadlight Global's footprint through the introduction of carbon reduction strategies.
- Continually respond to the future consequences of climate change by aligning our business strategy to emerging market trends and embedding sustainability within our corporate culture.
- Enhancing our company reputation by cutting down and reducing our carbon, water and energy costs and waste management.
- Assess the carbon and environmental impacts and risks across both our supply and value chain, then setting practical strategies and targets that deliver efficiency and mitigate risks.
- Constantly communicating the value of sustainability to all our customers and stakeholders.
- To continually work with our global networks, our people, the Government and businesses to positively promote that we can create a better future for everyone.

Signed for and on behalf of Broadlight Global Ltd
Steven O'Keefe, Director of Broadlight Global Ltd

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Data Protection

We hold personal data about our employees, clients, suppliers and other individuals for a variety of business purposes.

This policy sets out how we seek to protect personal data and ensure that staff understand the rules governing their use of personal data to which they have access in the course of their work. In particular, this policy requires staff to ensure that the Data Protection Officer (DPO) be consulted before any significant new data processing activity is initiated to ensure that relevant compliance steps are addressed.

Business Purposes
The purposes for which personal data may be used by us:
Personnel, administrative, financial, regulatory, payroll and business development.

Business purposes include the following:
-Compliance with our legal, regulatory and corporate governance obligations and good practice.
-Gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests.
-Ensuring business policies are adhered to (such as policies covering email and internet use).
-Operational reasons, such as recording transactions, training and quality control, ensuring the confidentiality of commercially sensitive information, security vetting, credit scoring and checking.
-Investigating complaints.
-Checking references, ensuring safe working practices, monitoring and managing staff access to systems and facilities and staff absences, administration and assessments.
-Monitoring staff conduct, disciplinary matters.
-Marketing our business.
-Improving services.

Personal Data
Information relating to identifiable individuals, such as job applicants, current and former employees, agency, contract and other staff, clients, suppliers and marketing contacts.
Personal data we gather may include: individuals' contact details, educational background, financial and pay details, details of certificates and diplomas, education and skills, marital status, nationality, job title, and CV.

Sensitive Personal Data
Personal data about an individual's racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings—any use of sensitive personal data should be strictly controlled in accordance with this policy.

This policy applies to all staff. You must be familiar with this policy and comply with its terms. This policy supplements our other policies relating to internet and email use. We may supplement or amend this policy by additional policies and guidelines from time to time. Any new or modified policy will be circulated to staff before being adopted.

Who is responsible for this policy?
As our Data Protection Officer, Michael Rudenko has overall responsibility for the day-to-day implementation of this policy.

Our Procedures
Fair and lawful processing.

We must process personal data fairly and lawfully in accordance with individuals’ rights. This generally means that we should not process personal data unless the individual whose details we are processing has consented to this happening.

The Data Protection Officer's Responsibilities:
• Keeping the board updated about data protection responsibilities, risks and issues
• Reviewing all data protection procedures and policies on a regular basis
• Arranging data protection training and advice for all staff members and those included in this policy
• Answering questions on data protection from staff, board members and other stakeholders
• Responding to individuals such as clients and employees who wish to know which data is being held on them by Broadlight Global
• Checking and approving with third parties that handle the company’s data any contracts or agreement regarding data processing

Responsibilities of the IT Manager:
• Ensure all systems, services, software and equipment meet acceptable security standards
• Checking and scanning security hardware and software regularly to ensure it is functioning properly
• Researching third-party services, such as cloud services the company is considering using to store or process data

Responsibilities of the Marketing Manager:
• Approving data protection statements attached to emails and other marketing copy
• Addressing data protection queries from clients, target audiences or media outlets
• Coordinating with the DPO to ensure all marketing initiatives adhere to data protection laws and the company’s Data Protection Policy

The processing of all data must be:
• Necessary to deliver our services
• In our legitimate interests and not unduly prejudice the individual's privacy
• In most cases this provision will apply to routine business data processing activities.

Our Terms of Business contains a Privacy Notice to clients on data protection.
The notice:

• Sets out the purposes for which we hold personal data on customers and employees
• Highlights that our work may require us to give information to third parties such as expert witnesses and other professional advisers
• Provides that customers have a right of access to the personal data that we hold about them

Sensitive Personal Data
In most cases where we process sensitive personal data, we will require the data subject's explicit consent to do this unless exceptional circumstances apply or we are required to do this by law (e.g. to comply with legal obligations to ensure health and safety at work). Any such consent will need to clearly identify what the relevant data is, why it is being processed and to whom it will be disclosed.

Accuracy and Relevance
We will ensure that any personal data we process is accurate, adequate, relevant and not excessive, given the purpose for which it was obtained. We will not process personal data obtained for one purpose for any unconnected purpose unless the individual concerned has agreed to this or would otherwise reasonably expect this.

Individuals may ask that we correct inaccurate personal data relating to them. If you believe that information is inaccurate you should record the fact that the accuracy of the information is disputed and inform the DPO, Michael Rudenko.

Your Personal Data
You must take reasonable steps to ensure that personal data we hold about you is accurate and updated as required. For example, if your personal circumstances change, please inform the Data Protection Officer so that they can update your records.

Data Security
You must keep personal data secure against loss or misuse. Where other organisations process personal data as a service on our behalf, the DPO will establish what, if any, additional specific data security arrangements need to be implemented in contracts with those third party organisations.

Storing Data Securely
• In cases when data is stored on printed paper, it should be kept in a secure place where unauthorised personnel cannot access it
• Printed data should be shredded when it is no longer needed
• Data stored on a computer should be protected by strong passwords that are changed regularly. We encourage all staff to use a password manager to create and store their passwords.
• Data stored on CDs or memory sticks must be locked away securely when they are not being used
• The DPO must approve any cloud used to store data
• Servers containing personal data must be kept in a secure location, away from general office space
• Data should be regularly backed up in line with the company’s backup procedures
• Data should never be saved directly to mobile devices such as laptops, tablets or smartphones
• All servers containing sensitive data must be approved and protected by security software and strong firewall.

Data Retention
We must retain personal data for no longer than is necessary. What is necessary will depend on the circumstances of each case, taking into account the reasons that the personal data was obtained, but should be determined in a manner consistent with our data retention guidelines.

Transferring Data Internationally
There are restrictions on international transfers of personal data. You must not transfer personal data anywhere outside the UK without first consulting the Data Protection Officer.

Subject Access Requests
Please note that under the Data Protection Act 1998, individuals are entitled, subject to certain exceptions, to request access to information held about them. If you receive a subject access request, you should refer that request immediately to the DPO. We may ask you to help us comply with those requests. Please contact the Data Protection Officer if you would like to correct or request information that we hold about you. There are also restrictions on the information to which you are entitled under applicable law.

Processing Data in Accordance with the Individual's Rights
You should abide by any request from an individual not to use their personal data for direct marketing purposes and notify the DPO about any such request. Do not send direct marketing material to someone electronically (e.g. via email) unless you have an existing business relationship with them in relation to the services being marketed. Please contact the DPO for advice on direct marketing before starting any new direct marketing activity.

All staff will receive training on this policy. New joiners will receive training as part of the induction process. Further training will be provided at least every two years or whenever there is a substantial change in the law or our policy and procedure.

Training is provided through an in-house seminar on a regular basis.
It will cover:
• The law relating to data protection
• Our data protection and related policies and procedures.

Completion of training is compulsory.

GDPR Provisions
Where not specified previously in this policy, the following provisions will be in effect on or before 25 May2018.
Privacy Notice - transparency of data protection
Being transparent and providing accessible information to individuals about how we will use their personal
data is important for our organisation.

The following are details on how we collect data and what we will do with it:
What information is being collected?
Information relating to the employment and implementation of employment and consultancy services.

Who is collecting it?
Broadlight Global

How is it collected?
Electronic submission

Why is it being collected?
For processing identity and background checks, human resources records, taxation, payroll and employment data.

How will it be used?

Who will it be shared with?
Where a consultant is assigned to a client, their details will be shared to a degree agreed to ensure the consultancy business can continue. Where a candidate is submitted for employment, records will be passed to the client as agreed with human resources requirements.

Identity and contact details of any data controllers.

Details of transfers to third country and safeguards.

Retention period
Duration of employment plus any required retention for taxation, payroll and employment data purposes.

Conditions for Processing
We will ensure any use of personal data is justified using at least one of the conditions for processing and this will be specifically documented. All staff who are responsible for processing personal data will be aware of the conditions for processing. The conditions for processing will be available to data subjects in the form of a privacy notice.

Justification for Personal Data
We will process personal data in compliance with all six data protection principles. We will document the additional justification for the processing of sensitive data, and will ensure any biometric and genetic data is considered sensitive.

The data that we collect is subject to active consent by the data subject. This consent can be revoked at anytime.

Criminal Record Checks
Any criminal record checks are justified by law. Criminal record checks cannot be undertaken based solely on the consent of the subject.

Data Portability

Upon request, a data subject should have the right to receive a copy of their data in a structured format. These requests should be processed within one month, provided there is no undue burden and it does not compromise the privacy of other individuals. A data subject may also request that their data is transferred directly to another system. This must be done for free.

Right to be Forgotten
A data subject may request that any information held on them is deleted or removed, and any third parties who process or use that data must also comply with the request. An erasure request can only be refused if an exemption applies.

Privacy by Design and Default
Privacy by design is an approach to projects that promote privacy and data protection compliance from the start. The DPO will be responsible for conducting Privacy Impact Assessments and ensuring that all IT projects commence with a privacy plan. When relevant, and when it does not have a negative impact on the data subject, privacy settings will beset to the most private by default.

International Data Transfers
No data may be transferred outside of the EEA without first discussing it with the data protection officer. Specific consent from the data subject must be obtained prior to transferring their data outside the EEA.

Data Audit and Register
Regular data audits to manage and mitigate risks will inform the data register. This contains information onwhat data is held, where it is stored, how it is used, who is responsible and any further regulations orretention timescales that may be relevant.

Reporting Breaches
All members of staff have an obligation to report actual or potential data protection compliance failures.This allows us to:
• Investigate the failure and take remedial steps if necessary
• Maintain a register of compliance failures
• Notify the Supervisory Authority (SA) of any compliance failures that are material either in their own right or as part of a pattern of failures

Please refer to our Compliance Failure Policy for our reporting procedure.

Everyone must observe this policy. The DPO has overall responsibility for this policy. They will monitor it regularly to make sure it is being adhered to.

Consequences of Failing to comply
We take compliance with this policy very seriously. Failure to comply puts both you and the organisation at risk. The importance of this policy means that failure to comply with any requirement may lead to disciplinary action under our procedures which may result in dismissal. If you have any questions or concerns about anything in this policy, do not hesitate to contact the DPO.

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It is our policy to conduct all of our business in an honest and ethical manner. We take a professionally, fairly and with integrity in all our dealings wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery.

Who is covered by the policy?
This policy applies to all individuals working at all levels and grades, including senior managers, directors, employees (whether permanent, fixed-term or temporary),consultants, contractors, and any other person providing services to us.

What is a bribe?
A bribe is a financial or other advantage offered or given: - to anyone to persuade them to or reward them for performing their duties improperly or; - to any public official with the intention of influencing the official in the performance of his duties.

Gifts and Hospitality
This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must comply strictly with Domino’s ethics policy in respect of gifts and hospitality. We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official in the performance of his duties.

Facilitation payments and kickbacks
We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. Kickbacks are typically payments made in return for a business favour or advantage. All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

Record Keeping
7.1 We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.
7.2 All expense claims relating to hospitality, gifts or expenses incurred to third parties must be submitted in accordance with our expenses policy and specifically record the reason for the expenditure.
7.3 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

Raising Concerns
Employees will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, even if  out to be mistaken.

The effectiveness of this policy will be regularly reviewed by the Board.  Internal control systems and procedures will be subject to audit under the internal audit process. 

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Trans Equality

Broadlight Global Ltd will not discriminate against people on the grounds of their gender identity or gender expression. This document uses the term ‘trans people’, which covers a range of trans communities including transsexual, intersex, agender, non-binary, non-gender or genderfluid identities and expressions. Broadlight Global will treat all employees, clients and third-party suppliers or contractors with respect and we seek to provide a positive environment that is free from discrimination.

Actions that we take include:

• Employees, clients and third-party suppliers or contractors will have fair treatment regardless of gender identity or because they propose to or have transitioned. Broadlight Global employees will not be in any way excluded from employment, training or promotion opportunities because of their gender identity or expression.

• Requests that are made to change name/s and gender on any data held by Broadlight Global will be handled promptly with all employees made aware of these changes and any implications that may come about as a result.  

• Confidentiality of all trans employees is of the utmost importance and information will not be revealed unless with consent to whom the information pertains to. Broadlight Global are supportive of employees who wish to share their trans status. This is a personal decision, and we encourage the individual to make the best decision for them in relation to their identity, expression or history.  

• Transphobic abuse, violence, harassment or bullying are serious offences and will be dealt with under formal disciplinary procedure noted in all employee contracts. Unacceptable behaviour may include purposeful mis-gendering or dead-naming, derogatory or stereotypical jokes, unwanted behaviour and intrusive questioning of individuals.  

• We will consult with trans employees, and the wider trans community, to ensure facilities and resources offered for employees are of a good standard and meet the needs of the user. When an issue with facilities or resources is brought to Broadlight Global, the DEI committee will oversee it’s handling and ensure our commitment to our employees is fair and equal.

• Any and all content created by Broadlight Global is subject to checks to ascertain it is free from discrimination, harassment, nor any reinforcement of harmful stereotypical assumptions about trans people. Instead, content will portray trans lives, trans people and trans experience positively.  

• Assumptions can be harmful and Broadlight Global seeks to eradicate assumptions of gender internally [employees, friends, partners] and externally [clients, suppliers and contractors] with all those that we engage with.