Modern Slavery Policy 1.2

Modern Slavery Act

Document Classification: Alchemy-wide policy (General)

Version: 1.3

Last annual review: 11 September 2023

Last Updated: 11 September 2023

Approver: Alchemy Board of Directors

Policy Statement:

Alchemy has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships. We expect the same high standards from all of our contractors, suppliers,and other business partners. We expect them to adopt the same zero-tolerance approach to the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect our suppliers to hold their own suppliers to the same high standards.


Alchemy Telco Solutions Limited and its subsidiaries (“Alchemy”) is a global multi-disciplinary technology company specializing in services within the circular economy. As of 31 March 2023, Alchemy employed over 250 employees in 10 countries.

This Modern Slavery Act Transparency Statement (“Statement”) outlines the actions undertaken by Alchemy entities that are within scope of section 54 (1) of the UK Modern Slavery Act 2015 (the Act) in relation to activities undertaken to identify and mitigate the risk of modern slavery and human trafficking occurring in its supply chain or business operations for the year ending 31 March 2023.

Policies and Processes

Alchemy supports fundamental human rights as set out in the Universal Declaration of Human Rights and core International Labour Organisation Conventions. In line with the UN Guiding Principles on Business and Human Rights, Alchemy recognises the duty of States to protect human rights and the responsibility of businesses to respect human rights.

Alchemy aims to identify and mitigate the risk of modern slavery and human trafficking occurring within its supply chain or business operations. Alchemy has an established set of policies and procedures that govern the way it operates. These are relevant to how Alchemy manages potential human rights-related issues regarding its employees and supply chain, and include:

  • Code of conduct;

  • Anti-Bribery and Corruption Policy

  • Gifts and Hospitality Policy

  • Employment Screening Policy;

  • Employment Handbook

  • Whistleblower Program


Alchemy is committed to a safe workplace that values equal opportunity, is free from discrimination, harassment and victimisation. Alchemy has robust policies and procedures concerning employment screening, employment conditions, and appropriate workplace behaviour. All staff are expected to abide by the spirit, as well as the strict requirements, of those policies and procedures.


Alchemy has over 40 suppliers across 12 countries who support the business in the provision of labour, materials, equipment, premises, professional services, and financial services.

Alchemy is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. Alchemy’s policies and procedures reflect its commitment to acting ethically and with integrity in all its business relationships and in implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its supply chains.

Suppliers are expected to address their compliance with human rights; safe, fair and ethical working conditions; environmental performance; and supplier diversity. The Alchemy supplier management system involves regular supplier reviews and performance tracking to:

  • Identify and assess potential risk areas.

  • Mitigate the risk of slavery and human trafficking occurring.

  • Monitor potential risk areas.

  • Protect whistle-blowers.

Training and capacity

Every year compulsory Code of Conduct training is given to all employees through an on-line e-learning module

Continuous improvement

Alchemy will review and enhance its approach to addressing modern slavery risks within its supply chain and parts of its business operations by:

  • Working with its suppliers to agree on principles of supply;

  • Engaging with relevant suppliers regarding the Modern Slavery Act requirements

  • Delivering supplier management training to employees on human rights and modern slavery risk in relevant supply chains.


This Modern Slavery Act Transparency Statement was approved by the Alchemy Board and will be updated annually.

The Board or governing body of each reporting entity has considered and approved this Statement prior to publication

Gary Noone Chairperson For and on behalf of Alchemy Telco Solutions Limited September 202

Alchemy ranked in Deloitte Technology Fast 50