Introduction
This Modern Slavery and Human Trafficking Statement relates to the financial year ending 31 July 2025. It is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes COOLSPIRiT, a Databarracks company's slavery and human trafficking statement.
COOLSPIRiT, a Databarracks company is committed to preventing slavery and human trafficking in our business activities and supply chains. We have a duty to be alert to risks, however small. Staff are expected to report concerns and management to act upon them.
Organisational structure and supply chains
COOLSPIRiT, a Databarracks company is a UK-based technology solutions provider, delivering tailored data protection, cyber security and hybrid infrastructure solutions.
Our supply chains include technology and hardware suppliers (data centre infrastructure, server and storage hardware, networking equipment, software licensing), telecommunications providers, facilities management, professional services, recruitment agencies and specialised technical contractors.
We recognise higher risks in hardware manufacturing in Asia, software development and IT services, lower-tier technology suppliers, contracted cleaning and facilities services and agency labour.
Policies
Our approach to preventing modern slavery is embedded in the following policies:
Whistleblowing Policy: Encourages reporting of concerns related to our activities or supply chains
Code of Conduct: Sets expectations for ethical business practices and human rights
Environmental Policy Statement: Includes ethical sourcing considerations
Corporate Social Responsibility Policy: Outlines our commitment to ethical labour practices
Recruitment and Employment Policy: Ensures right to work verification, written employment terms, National Living Wage compliance, and prohibits withholding identity documents or requiring deposits
Due diligence processes
Supplier onboarding: All new suppliers complete pre-qualification screening questionnaires covering modern slavery policies and labour practices. We conduct risk assessments based on geographic location, industry sector and service nature and request modern slavery statements and evidence of labour law compliance.
Ongoing management: We build long-standing supplier relationships with clear expectations, conduct annual reviews of key suppliers, include Modern Slavery Act compliance clauses in all contracts with audit rights, and conduct on-site audits or third-party certification verification for high-risk suppliers.
Remediation: If concerns arise, we immediately investigate, develop corrective action plans with timelines, monitor progress and terminate relationships if adequate improvements are not made.
Risk assessment and management
High risk areas
Hardware manufacturing supply chain: Electronics manufacturing in Asia may involve vulnerable workers. We prioritise suppliers with robust CSR policies and third-party certifications, requesting supply chain transparency beyond tier-1 suppliers.
Facilities and cleaning services: Contract services can involve vulnerable or migrant workers. We conduct right-to-work checks, ensure National Living Wage compliance and maintain direct relationships with service providers.
Agency and temporary labour: Temporary workers may face exploitative practices. We use only reputable recruitment agencies who are professional body members, verify employment status and right to work and ensure equal pay and conditions.
Medium risk areas
Data centre operations: Construction and maintenance may involve subcontracted labour. We engage with providers to understand their due diligence and require compliance evidence.
International operations: Different labour standards exist across locations. We conduct regular employment practice audits, maintain local HR oversight and exceed local legal minimums.
Training
Mandatory training
Modern slavery awareness: We make all training available for employees to complete – covering understanding modern slavery, recognising warning signs, reporting procedures and company policies.
Enhanced due diligence: Procurement, Finance, HR teams and Senior Management hold meetings to discuss supply chain risks, supplier assessment and due diligence procedures.
Recruitment and onboarding: HR and Hiring Managers receive training on right-to-work verification, identifying vulnerable workers and fair recruitment practices.
Training effectiveness is measured through activities such as, but not limited to: completion rates, post-training assessments, incident reviews, feedback surveys and procurement decision integration.
Responsibility
- Group Board of Directors: Ultimate responsibility for compliance
- HR Consultant: Policy development and training
- Resilience Director: Risk assessments
- Sales Director and Finance Director: Due diligence with suppliers and customers
- Procurement Lead: Supplier due diligence implementation
- HR Consultant and Managing Director: Investigation of reported concerns
Approval
This statement will be regularly reviewed and updated at company group level. The group Board of Directors endorses this policy and is fully committed to its implementation.
Approved by:
Name: James Watts
Position: Managing Director (Databarracks Limited)
Date: 11 December 2025
