JSI's Modern Slavery Statement
Pursuant to Section 54 (1) of the United Kingdom (UK) Modern Slavery Act 2015, Jatom Systems Inc. (JSI) states we have taken steps during the past fiscal year to identify and minimize the risk of slavery and human trafficking taking place in our supply chains and in any part of our business. This statement is applicable to JSI and all its subsidiaries for the fiscal year ended March, 31, 2022.
Our expectations for responsible, ethical and legal conduct are applicable to all parties who work on behalf of JSI, including but not limited to our employees, partners, contractors, and other representatives that act on behalf of JSI and to our vendors and suppliers. This expectation is at the core of our corporate culture and all our business practices as we support the mission of our customers, law enforcement and intelligence agencies worldwide.
Organization Structure and Supply Chains
JSI is a privately held, Canadian controlled corporation, incorporated in Ontario and headquartered in Kanata. It has four whole-owned subsidiaries located in Australia, Germany, the United Kingdom and the United States. Together, with its’ subsidiaries, JSI develops, sells and supports data collection and data analytics solutions for law enforcement and intelligence agencies worldwide.
JSI’s solutions are comprised of proprietary software developed at our Kanata headquarters and third party software and hardware provided by our suppliers. In addition to our solutions, JSI offers professional services, training and post-sales support. In the provision of our proprietary software and related services, JSI employs professionally qualified individuals directly employed by JSI or one of its subsidiaries. Our people policies ensure the fair treatment of our people around the world. Our suppliers are, generally, large multi-national companies headquartered in North America. JSI relies on the ethical conduct and modern slavery policies of our suppliers to ensure the prohibition and minimization of the risk of slavery and human trafficking in our supply chain.
Policies in relation to slavery and human trafficking
Our business purpose is to support law enforcement and intelligence agencies in the achievement of their missions to protect the most vulnerable members of society from criminal activity. In delivering on our purpose, our values of respect and integrity are the cornerstone of our culture. Our values embody all that we do at JSI and outline our expectations for our people’s behaviour towards colleagues, customers and vendors.
We seek to treat all individuals fairly and consistently in an open and trusted environment. Our policies related to the Modern Slavery Act are in line with our culture and values. More specifically, for the jurisdictions in which we operate, we:
- Follow a robust recruitment process in line with relevant employment laws
- Ensure all employees meet the ethical conduct and integrity standards to receive secret security clearance
- Adhere to employment policies that protect our people from unfair treatment and promote a fair and inclusive workplace
- Review market related pay and other compensation annually
- Provide policies and initiatives to support our employees’ physical and mental well being
With respect to our supply chain for third party software and hardware, JSI relies on the due diligence and review processes of our key suppliers to ensure modern slavery and human trafficking are not present within their supply chains. Reliance on supplier due diligence, coupled with ensuring our own understanding of component parts and their related country of origin are critical business processes to ensure we are in:
- Compliance with all import/export regulations for the countries in which we do business.
- Compliance with all sourcing standards given the sensitive and, often, classified nature of our customer base.
All purchases are with duly approved vendors, following a procurement authorization process. JSI does not pay cash for products or services.
Due Diligence process, Risk Assessment and Management
JSI manages its potential ongoing risk through appropriate core business processes including procurement processes. All procurement must be from approved suppliers and supplier performance is regularly monitored. JSI does not wish to be associated with any organization that either has or is found to be involved in either human trafficking or modern slavery. Should JSI become aware that human trafficking or modern slavery were present within the supply chain of our vendors, JSI would require the supplier to remediate the situation to JSI’s satisfaction else the business relationship would be terminated.
Key performance indicators to measure effectiveness of steps
To date, we have not identified any instances of modern slavery occurring in our supply chain and therefore it can be difficult to measure the effectiveness of our policies in reducing the risk of slavery and human trafficking.
Training on modern slavery and trafficking
JSI’s expectations for employee conduct are routinely reviewed and discussed with employees through our quarterly performance management process. In addition, security clearance requirements for ethical behaviour are monitored periodically by our internal security team as well as externally by the responsible agency for the jurisdiction in which we employ individuals.
JSI takes responsibility for this Statement and its related objectives and will review and update it in accordance with The Act.