Introduction

This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 December 2021.

Great Wave AI (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational structure

Great Wave AI has business operations in the United Kingdom.

We operate in the technology sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers, who provide us with goods, such as equipment for our premises, and services, such as outsourced business processes, professional services, IT software and marketing services.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted the following due diligence procedures:

• Internal supplier audits.

Our due diligence procedures aim to:

• Identify and action potential risks in our business and supply chains.
• Monitor potential risks in our business and supply chains
• Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through:

• Evaluating the slavery and human trafficking risks of each new supplier.

We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as software and services. We are also a micro-business with less than 5 staff so we are very aware of all decisions being made on the business’ behalf.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.

Effectiveness

The Company uses Key Performance Indicators (KPIs) to measure its effectiveness and ensure that slavery and human trafficking is not taking place in its business and supply chains. These KPIs are as follows:

• We will contact suppliers to enquire about their modern slavery practices every 6 months.
• We will train our staff about modern slavery issues and increase awareness within the Company.

Training our staff

The Company requires its staff to complete training and ongoing refresher courses on slavery and human trafficking. The Company’s training covers:

• How to identify the signs of slavery and human trafficking.
• What initial steps should be taken if slavery or human trafficking is suspected.
• How to escalate potential slavery or human trafficking issues to the relevant parties within the Company.
• What external help is available.
• What steps the Company should take if suppliers in its supply chain do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company’s supply chain.

The statement was approved by the board of directors.

Jack Perschke, Director