1. Our position
Virtual Era Ltd. has zero tolerance for modern slavery, forced labour, child labour, debt bondage, and human trafficking in any part of our operations or supply chain. This statement describes the steps we take to identify, prevent, and address such risks.
2. Reference framework
This statement is informed by:
- The Universal Declaration of Human Rights and the core conventions of the International Labour Organization.
- The United Kingdom Modern Slavery Act 2015, where applicable to our operations in the United Kingdom or to our UK clients.
- Directive (EU) 2024/1760 (the Corporate Sustainability Due Diligence Directive, "CSDDD") in respect of the human rights and environmental due diligence expectations it sets out.
- Regulation (EU) 2024/1335 prohibiting products made with forced labour on the Union market.
- National labour and human-rights legislation in each operating jurisdiction.
The statement is reviewed annually and updated as our operations, supply chain, or the legal framework develop.
3. Our structure and operations
Virtual Era Ltd. is incorporated in the Republic of Kosova with operations in Kosova, Albania, North Macedonia, and Montenegro, and engagements with clients across the Balkans, the European Union, and beyond. Our workforce is composed primarily of engineers, consultants, and operational staff employed directly by Virtual Era or by group-affiliated entities. We engage contractors, professional advisers, suppliers of technology and services, and partners of various types.
4. Our supply chain
Our supply chain consists primarily of:
- Technology vendors and software publishers from whom we resell, integrate, or operate solutions.
- Cloud infrastructure providers and managed-service partners.
- Professional services providers (legal, audit, tax, training).
- Office and facilities suppliers.
- Travel and logistics providers.
The majority of our spend is with suppliers headquartered in the European Union, the United Kingdom, the United States, and the wider OECD. We engage with a smaller number of suppliers headquartered in other regions, on a vetted basis.
5. Policies in place
Virtual Era maintains policies relevant to modern slavery prevention:
- Code of Conduct — sets out the ethical principles expected of all Virtual Era personnel.
- Supplier Code of Conduct — expected adherence by all suppliers; included by reference in standard procurement contracts.
- Recruitment Policy — verifies the right to work and prohibits any practice that constitutes forced labour, including the withholding of identity documents or the charging of recruitment fees to candidates.
- Whistleblowing Policy — published at virtualera.net/legal/whistleblowing, with protected reporting channels for concerns including human rights violations.
- Procurement Policy — integrates human-rights and modern-slavery considerations into supplier due diligence.
6. Due diligence
Our human-rights and modern-slavery due-diligence approach proceeds in proportionate steps:
- Risk identification — mapping our supply chain by category, geography, and sector to identify higher-risk areas. Categories such as electronics manufacturing, raw materials, and certain professional services in high-risk jurisdictions receive enhanced scrutiny.
- Supplier screening — pre-onboarding checks against public sanctions and sanctions-related lists, adverse-media screening, and reference checks. Higher-risk categories receive deeper supplier questionnaires.
- Contractual safeguards — modern-slavery and human-rights clauses in standard procurement contracts, with audit rights for higher-risk suppliers.
- Ongoing monitoring — periodic re-screening, monitoring of adverse media, and a complaints and grievance channel accessible to suppliers and their personnel.
- Remediation — where a risk or actual harm is identified, a remediation plan is developed in cooperation with the supplier, including timelines, monitoring, and where appropriate contract termination.
7. Training
Personnel involved in recruitment, procurement, vendor management, and operations receive training on modern-slavery awareness at induction and annually thereafter. Additional training is provided to staff working in higher-risk categories or markets.
8. Indicators and measurement
Indicators we track include:
- Number of suppliers screened against modern-slavery risk criteria.
- Number and outcomes of supplier audits triggered by elevated risk indicators.
- Number of whistleblowing or grievance reports related to human-rights or modern-slavery concerns.
- Coverage of modern-slavery training across relevant personnel.
Material findings are reported to the Audit Committee and inform the next annual review of this statement.
9. Concerns and reporting
Any person — employee, supplier personnel, client, or external party — who suspects that modern slavery or human trafficking may be occurring in Virtual Era’s operations or supply chain is asked to report through the secure channels described in our Whistleblowing Policy. Protection from retaliation applies as set out in that policy.
10. Approval
This statement is approved by the Board of Directors of Virtual Era Ltd. and signed by its Chief Executive on behalf of the company. The statement is reviewed and republished at least annually.
11. Contact
Questions about this statement: compliance@virtualera.net.