Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps Aculom will take to ensure our business and supply chains are free from modern slavery. It was approved by the Company on 1st February 2018.

Our Organisation and Structure

Aculom Limited have exclusively partnered with Tokinomo to deliver the most effective and innovative Point of Sale marketing solution to the Retail Marketplace in the U.K.

The primary departments which have their separate sub-divisions are Sales & Marketing, Operations, Finance, and Human Resources.

We operate from three facilities nationally with the physical operational activity being undertaken by sub-contractors.

Our supply chains include suppliers for office facilities services such as office cleaning and maintenance; specialist for the installation, monitoring, maintenance and de-installation of the Tokinomo devices; we also use advisers for specialist services including consultants providing services specific to the undertakings of the department across the organisation.

Due Diligence Process

Aculom have commenced its investigations into modern slavery.  We trust that our due diligence process and the necessary steps required will evolve as we continue the process responsibly.

Although the Point of Sale sector is low risk for modern slavery to be prevalent, in order to effectively accomplish our initiative to alleviate the risk of forced labour, we will conduct audits of our existing suppliers to ensure that forced labour and human trafficking is not taking place in our supply chain.  To accomplish this going forward:

  • New suppliers will be subject to due diligence checks to evaluate the risk of forced labour before commencing any works on behalf of Aculom,
  • Each member of the Executive team will undertake a risk analysis of their supply chain to examine the risks of modern slavery and human trafficking,
  • Furthermore, they will ensure that their respective departments are conscious of modern slavery
  • We will continually monitor the risks in our supply chain,
  • We will update or produce necessary documentation to express our commitment to ensuring modern slavery and human trafficking is not taking place within our supply chain.

Due to the variation of our supply chain, the sensitivity and complexity of Modern slavery, we recognise that it is challenging to wholly govern our suppliers’ moral principles.  However, we will effectively communicate to our supply chain that any form of modern slavery is not tolerated.


In order to understand the potential risks of modern slavery, human trafficking and child labour we will request for all our suppliers who may be susceptible to modern slavery to provide relevant training to all their staff.

Internally, we will provide training to members of staff responsible for engaging new suppliers to be aware of the risks of modern slavery and the due diligence process to follow.

Monitoring the effectiveness

Following the risk analysis each department has conducted, the results will be examined to determine what further action is required to ensure we effectively eradicate modern slavery from our supply chain.