Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Pure DC has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place within the business or in any of our supply chains.
Pure DC is a UK-based organisation specialising in the design, construction, and operation of data centres across multiple global regions. We have operations across the UK, Europe, the Middle East, and Asia. Our organisational structure includes regional offices, and a network of subsidiaries, and our key supply chains include:
- Construction materials and services
- Mechanical and electrical equipment
- IT infrastructure and hardware
- Facilities management and cleaning services
- Professional services (legal, financial, consultancy)
Given the global nature of our operations, we recognise the risk of modern slavery in certain regions and sectors, particularly in construction and manufacturing. Our supply chains span multiple countries, and we recognise that some of these supply chains may carry a higher risk of modern slavery, particularly those involving outsourced labour or suppliers operating in high-risk regions, and we are committed to managing these risks proactively. Pure DC is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the UK Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and require compliance with all applicable national and international anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force. We also expect that our contractors, suppliers and other business partners will hold their own suppliers to the same high standards.
To support these commitments, Pure DC has implemented the following policies:
- Anti-Slavery and Human Trafficking Policy
- Code of Conduct
- Whistleblowing Policy
- Group Procurement Policy
These policies are reviewed regularly and are communicated to all employees and key suppliers.
Pure DC undertakes due diligence when considering taking on new suppliers and regularly reviews its existing supply chains. Our due diligence and supplier onboarding processes include assessing risks of modern slavery, focussing on geographic and sector specific risks. We require high-risk suppliers to provide evidence of their anti-modern slavery practices, including their own policies, declarations of compliance, and where appropriate, conducting audits or site visits.
To measure the effectiveness of our efforts to combat modern slavery, we monitor the number of supplier audits completed, training completion rates, and any reported incidents of non-compliance. These indicators are reviewed annually and used to inform improvements to our policies and practices.
Training is provided to all staff to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business. Training is refreshed annually and updated to reflect emerging risks and best practices. In addition, our code of conduct establishes a set of common standards and business behaviours that everyone at Pure DC should follow, including our support of the principles set out in the United Nations Universal Declaration of Human Rights.
This statement and the Pure DC Anti-Slavery and Human Trafficking Policy have been approved by the Board of Directors and are reviewed annually. They apply to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners. This statement covers the financial year ended 31 December 2024, and covers all Pure DC subsidiaries.
This statement was reviewed and approved by the Board of Directors on 30 June 2025.