Published voluntarily. Section 54 of the Modern Slavery Act 2015 applies at £36 million turnover and ETABLIX is below it — so no statement is required. The threshold measures turnover, not exposure, and this company specifies what other people buy.
This statement is voluntary. Section 54 of the Modern Slavery Act 2015 requires a statement from organisations with a total annual turnover of £36 million or more. ETABLIX is below that threshold, so no statement is required, none is overdue, and the company is not in breach of section 54. Nothing here should be read as a claim that ETABLIX is subject to section 54.
ETABLIX does not tolerate slavery, servitude, forced or compulsory labour, or human trafficking in any part of its business or in any supply chain it specifies, recommends or manages. There is no commercial outcome that justifies it, no price that makes it acceptable, and no client instruction that authorises it. Where it is found, the work stops and it is reported — to the client, and to the authorities where the threshold for that is met.
JNN GLOBAL LTD, trading as ETABLIX, is a company with one working director and no other employees. That makes this statement shorter than a main contractor's. It does not make it weaker, and it does not make the risk smaller, because almost none of the risk sits inside this company.
Because the threshold measures turnover, not exposure. ETABLIX buys nothing at scale and specifies a great deal — and what it specifies is bought by somebody. A statement that waits for £36 million of turnover waits past the point at which it could have made a difference.
When the threshold is reached, this statement is brought within section 54 in that financial year: approved by the board, signed by a director, and published with a prominent link on the homepage, as section 54(6) and 54(7) require. It is written in that form now so that nothing has to change when it does.
ETABLIX has almost no supply chain of its own. It has substantial influence over other people's. The company buys a laptop, some software and professional services. What it specifies, runs enquiries for, compares and recommends is bought by the client — and it is bought in categories where labour exploitation in UK construction is most often found.
Internal risk: close to nil. One working director, engaged directly, paid through PAYE, with no recruitment intermediary anywhere in the arrangement. There is no plausible route to exploitation inside this company, and saying otherwise to appear diligent would be the tell.
The specification sets the price, and the price sets the terms. A cleaning or security package specified at a rate that cannot be delivered lawfully will still attract bidders, and the ones who bid it are the ones who intend to recover the difference somewhere. That somewhere is wages, hours, deductions or accommodation. Nobody has to intend any harm for this to happen — a benchmark rate carried forward from a job three years ago will do it on its own.
So the first control here is not a clause in a contract. It is that ETABLIX builds rates from the programme, the location and the actual labour requirement rather than from a benchmark, and declines to specify a package at a rate it cannot see being delivered lawfully.
The second is visibility. A main contractor knows its subcontractor; it frequently does not know its subcontractor's subcontractor, and the cleaning operative on a night shift is usually two tiers below the party holding the contract. Risk concentrates exactly where visibility stops, which is why every condition below applies down the chain rather than at the first tier.
These apply to any supplier ETABLIX specifies, recommends or engages, at every tier. They are written as short, checkable facts on purpose — a requirement that cannot be verified in a single question is a requirement nobody verifies.
They are issued with the enquiry documents rather than raised after selection. A supplier that cannot accept them at enquiry stage is not compared, and a bid that is cheaper because it has not accepted them is identified as such rather than simply ranked first.
ETABLIX recommends and the client pays. That is a limit on this company's control and it is stated rather than obscured: ETABLIX cannot terminate a supplier it did not contract with. What it can do is refuse to recommend, record why, and tell the client — and under this statement it does all three.
Anyone — a worker, a supplier, a client's staff, a member of the public — may raise a concern, and may do so anonymously. No person raising a concern in good faith will suffer any detriment from ETABLIX, and that protection applies whether or not the concern turns out to be well founded.
Suspicion is enough to report. A person raising a concern is not required to have evidence, to be certain, or to have identified an offence — establishing that is the authorities' job, and waiting for certainty is how these things continue.
Listed because a reader who finds a sixth item after being shown five stops believing the five.
Approved by the board of JNN GLOBAL LTD and signed by a director — the form section 54(6) requires, followed although the section does not yet apply. Reviewed annually and on any material change to the business or its supply chains, whichever comes first. Each revision states the year it covers, and earlier revisions are retained rather than replaced so the direction of travel can be read.
Justin Ngolu Nseya
Founder & Managing Director, ETABLIX — a Groupe Nseya brand
Full statement (PDF) · Supplier Code
