Purpose of this statement
This statement (the Statement) is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the Act) on behalf of Intel 471 UK Ltd. (Intel 471 UK), which is incorporated in England and Wales (Reg. No. 11823914). Intel 471 UK is a wholly owned subsidiary of Intel 471 Inc. of Delaware, USA (Intel 471).
Recorded in the Statement are the actions taken by Intel 471 during 2023 to ensure that modern slavery and human trafficking do not take place within its supply chain and is not in any way associated with its business.
Jason Passwaters, CEO of Intel 471, approved this Statement on December 1, 2023.
Our commitment
Our goals are to always be “doing the right thing,” and to work to the highest professional standards. Our commitment to these goals is reflected in how we run our business.
The UK government proposed an amendment to the Act in 2020 to require that any statement, produced pursuant to the Act, must include information on six areas. In anticipation of that proposed change, we set out in the Statement our response to each of the six proposed mandatory areas.
(1) Our structure, business, and supply chains
Intel 471 provides cyber threat intelligence reporting data and services and operates through offices, and subsidiaries in the United States, Singapore, Israel, United Kingdom, Estonia and Netherlands.
We are committed to working towards the elimination of any possibility of slavery in our supply chain. Intel 471’s supply chain is similar to the supply chain of other remote, digital businesses and is relatively simple. The key services we procure are professional services and information technology. The sourcing and purchasing of goods and services are managed by our executive team under the guidance of our Chief Financial Officer.
(2) Our policies
In addition to this Modern Slavery and Human Trafficking Statement, we have various other policies available to our team members, which provide information regarding the behavior we expect of them. These policies include our Code of Conduct and Security Policies and cover matters such as ethics, nondiscrimination, anti-harassment, and anti-bribery/anti-corruption/anti-money laundering.
(3) Our due diligence procedures
Upon onboarding, we review all Intel 471 suppliers using a risk-based approach and regularly thereafter. The assessment involves the consideration of a number of factors which are broadly (1) the location from which the service or goods are supplied, (2) the industry sector from which the services or goods are provided, and (3) the labor practices specific to the industry and the location from which the particular services or goods are supplied. The assessment started in the second quarter of 2023 and is expected to conclude by the end of the second quarter of 2024.
We anticipate implementing a contract management process in 2024 for use with all suppliers. This process will require that all new, potential suppliers provide evidence of their modern slavery and human trafficking policies.
(4) Risks of slavery or human trafficking in relation to our supply chain and business
Although we regard the provision of cyber threat intelligence as a business with a low risk of involvement with human trafficking and slavery, we are not complacent. We consider that in some areas, there are known concerns regarding human trafficking and slavery, for example, in illicit transactions undertaken on the dark web or using cryptocurrency. For these higher risk areas, we have implemented reporting requirements to allow for proper documentation and, if necessary, coordination with relevant authorities.
(5) Our effectiveness, measured against performance indicators that we consider appropriate
We continue to monitor and work to improve the systems in place to ensure that our business and supply chain are free from modern slavery.
UK Government guidance is that the effectiveness of measures taken by an organization to ensure that slavery and human trafficking is not taking place in its supply chain or business should be measured against key performance indicators. The Intel 471 executive team will review the following key performance indicators:
- The number of slavery suspicions reported;
- Employees policy compliance and training metrics;
- Responses from our suppliers during the due diligence processes.
Intel 471 is committed to upholding and promoting human rights through the manner in which it conducts business.
(6) Training and capacity building available to our employees and contractors
We have additional resources available to our team members regarding modern slavery and human trafficking via Human Resources.
Looking ahead
We regularly assess the modern slavery and human trafficking risk in our supply chain from our existing and new suppliers.
