Pocket NC Modern Slavery and Human Trafficking Statement

This statement relates to Pocket NC Company (“Pocket NC”) and addresses the Modern Slavery Act 2015 (‘the Act’). Herein we discuss the steps that Pocket NC Company has taken and continues to take to mitigate the risk of modern slavery within our supply chain and business and to conform with the requirements of the Act.

Our Business, Organizational Structure and Supply Chain

Pocket NC is a small manufacturer of desktop CNC milling machines located in Montana, USA with 10 employees. We have resellers and suppliers throughout the world, although we try to source as many components locally to support our community, control variables within our production process and support United States manufacturers to the fullest extent we are able. We ensure all suppliers provide quality products and to the best of our knowledge and within our procurement processes are compliant with the act.

Pocket NC’s Policies and Systems on Modern Slavery and Human Trafficking

Pocket NC is aware of its responsibility to have due diligence around Modern Slavery and Human Trafficking. As such Pocket NC expects all of its employees, resellers and suppliers to adhere to the policies, procedures and principles put in place around Modern Slavery and Human Trafficking. 

Modern Slavery Policy - Pocket NC is committed to acting with awareness in identifying and preventing unethical activities within the company, including awareness and prevention of modern slavery and/or human trafficking. We commit to acting ethically in all business relationships. We seek to implement and enforce processes and measures to ensure modern slavery is not taking place within our own business, reseller business and any part of the supply chain. If we became aware that any of our suppliers was in any way accepting modern slavery and/or human trafficking we would address and rectify the issue with the supplier immediately. 

The "Whistleblower" Policy - Pocket NC seeks to ensure that an employee may voice concerns about particular incidents or wrongdoing, or other suspected malpractice, without fear of discrimination. Pocket NC takes great pride in our strong commitment to ethical standards in the way we work. We support our employees to come forward when they believe or see there is wrongdoing in our workplace or supply chain. Our "Whistleblowing policy" is in place to outline the procedures employees can use to raise their concerns. 

Hiring Policy - Our hiring process includes conducting eligibility to work in the US checks for all directly employed staff as well as pre-employment references to safeguard against human trafficking or individuals being forced to work against their will. 

Risk Assessment & Due Diligence 

While we are a small business and have limited resources several ways in which we already conduct business work to address risk in modern slavery and human trafficking which include a commitment to local supply chain and selling an export restricted product which requires due diligence and awareness of how we are manufacturing our product as well as who we are selling product to. The key area of impact for our risk assessment is in our supply chain. 

Risk Assessment - Our supply chain is risk assessed using the following criteria to assess and manage risks to workers: 

Country risks: Pocket NC sources most components from the United States (>85%), Western Europe (<3%), Japan (<5%%), and China (<5%). These countries are lower on the spectrum of modern slavery risk. We hold our suppliers responsible for ensuring their supply chain is within compliance. 

Industry risks: Manufacturing does rank high on the industries affected by modern slavery and human trafficking however our product is manufactured and assembled within the United States in our facility. As such by bringing labor in house this risk is mitigated effectively. 

Business partnership risk: We have been working with key suppliers for the long term and as such have a good knowledge of our partner’s operations and policies. We have also recently put in place supplier terms and conditions specifically addressing modern slavery and human trafficking. All our reseller partners sign an agreement which includes upholding laws and regulations that include modern slavery and human trafficking in each one of the countries where we are reprsented by resellers. 

We will continue to assess and mitigate the risk of modern slavery and human trafficking, remining vigilent and review our processes and procedures to ensure appropriate risk mitigation is in place. We will not tolerate modern slavery in any form within any part of our business including suppliers and resellers. 

Training

Training and policies are available in the employee handbook and export compliance program which includes policies on employment and reporting violations of policies and procedures. We also provide updates as new information becomes available in team meetings. We are looking at ways to increase awareness within our organization, and to ensure understanding of the risks involved with modern slavery and human trafficking in our supply chains and business. 

This statement is made in accordance with Section 54 of the UK Modern Slavery Act 2015 for the financial year ending December 31, 2021.