Modern Slavery Act Statement

Modern slavery and human trafficking continue to be a tragic reality within modern society. It takes various forms, including actual slavery, enforced servitude, forced, or compulsory labour, and human trafficking, all of which have in common the deprivation of a person liberty by another for personal or commercial gain.

Tungsten Corporation Plc unreservedly condemns modern slavery and human trafficking wherever in the world it occurs and is committed to improving our practices to combat it.

Organisation’s Structure

Tungsten Corporation Plc is a global provider of technology solutions to enable businesses all around the world to digitise their purchase to pay solutions by using the Tungsten Network proprietary platform. This helps businesses streamline their accounts payable and accounts receivable processes, making them more cost and operationally efficient. In addition, the use of the platform contributes significantly to reducing the use of paper documents and carbon emissions.

Tungsten Corporation Plc is the parent company of the Tungsten group of companies.

The Group has over 300 employees worldwide and has operations in the following countries: the United Kingdom, USA, Bulgaria, and Malaysia.

Our Business

Our Operating businesses and their primary functions consist of:

  • Tungsten Network Ltd (London, UK) (Global Headquarters) (Corporate and Sales)
  • Tungsten Network Inc. (Atlanta, Georgia and Toledo, Ohio, both USA) (Regional Headquarters) (Sales and Operations)
  • Tungsten Network EOOD (Sofia, Bulgaria) (Support/Development)
  • Tungsten Network Sdn Berhad (Kuala Lumpur, Malaysia) (Internal F&A and Support).
  • Supply Chain

Our supply chain predominantly consists of underlying technology infrastructure providers, which, typically due to our demands of security and data protection, are internationally recognised providers in their fields.

Our Policy and Due Diligence Process

Tungsten Corporation Plc is committed to ensuring there is no modern slavery in its supply chain or in any part of its business.

Tungsten Corporation Plc has well-established Procurement, Legal and Compliance departments who interact and interface with each other to ensure that vendors are selected on the basis of their capability to conform to our demands in respect to complying with all relevant aspects of law, security and data protection including but not limited to complying with relevant anti-slavery and human trafficking law and other corporate and social policy requirements.

Further Steps

Additional Commitments from “High” risk Vendors
In addition, Tungsten Corporation Plc will next financial year initiate a regular risk assessment of the different types of supply so as to identify where there is the greatest risk of modern slavery or human trafficking being involved. For instance, the supply of telecommunications software or hardware is considered low risk; and the supply of low-value services in vulnerable countries is considered high risk.

For those considered higher risk, additional statements articulating what detailed steps they have taken may be required.

In addition to its existing whistleblower policy and its security, customer confidentiality and data protection training programme, Tungsten Corporation Plc will initiate a training programme to relevant employees to ensure there is a high-level awareness within the Group of the risks of modern slavery and human trafficking in our supply chains and our business.

In the instance that Tungsten Corporation Plc identifies high-risk vendors, due consideration will be taken to what KPIs may be relevant.

This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes Tungsten Corporation Plc’s slavery and human trafficking statement for the financial year ending 30 April 2019.

For and on behalf of Tungsten Corporation plc and its subsidiaries.

David Williams

Chief Financial Officer & Interim Chief Executive Officer

22nd July 2019

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