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This statement is written in the form required by section 54 of the UK Modern Slavery Act 2015, and it addresses in addition the mandatory criteria of section 16 of the Australian Modern Slavery Act 2018, the duties of the German Lieferkettensorgfaltspflichtengesetz of 16 July 2021, and the due diligence obligations of Directive (EU) 2024/1760 as amended by Directive (EU) 2026/470.

Whether an entity of the group falls within the turnover threshold set by SI 2015/1833 for the United Kingdom, the consolidated revenue threshold of section 5 of the Australian Act, or the employee thresholds of the German and European texts, is determined at the close of each financial year. The group does not publish turnover or headcount figures on this site, and this statement is published in the same form whether or not a threshold is met in a given year. The German law retains its due diligence duties; its reform removes the annual reporting obligation and refocuses penalties on serious breaches, without lowering the substantive standards according to the German government. It applies until the European directive is transposed, which is due by 26 July 2028, the obligations themselves applying from 26 July 2029.

Parousia Group is a privately held technology holding with its registered office at 157 avenue du Livre, Kinshasa – Gombe, Democratic Republic of the Congo, offices in the United States, the United Kingdom and Dubai, and a technical arm, Echad Technologies, in Singapore. It operates through five regional holding companies — Parousia West Africa in Lagos, Parousia East Africa in Nairobi, Parousia Europe in London, Parousia America in Washington and Parousia Middle East in Dubai.

The group operates six solutions: NetVox Intelligence in unified communications and applied artificial intelligence, Global Technology Africa in cloud and platforms, Afrika Plaza in commerce, PAGEXPRESS in logistics, PAGPay in payments, and INTIC in educational technology, which is under construction. What the group buys follows from what those solutions do, and the exposure to forced labour is concentrated in four categories rather than spread evenly across procurement.

The group contracts with distributors, integrators and service firms, and almost never with the plant that made the equipment or the agency that recruited the worker. That is the whole difficulty: a first-tier supplier can be entirely compliant while the practice that matters happens two or three tiers below it, in a country the contract never names. Stating the risk in that form is more useful than a promise that suppliers are respectable.

• Recruitment fees charged to workers, which turn a wage into a debt and a job into bonded labour. This is the single most common entry point into forced labour in electronics assembly, construction and guarding, and it is the indicator the group treats as decisive.
• Retention of identity documents and passports, restriction on freedom of movement, and accommodation controlled by the employer or the broker.
• Contract substitution — the terms signed in the country of origin replaced by worse terms on arrival — and wages withheld, deducted or paid late.
• Excessive overtime presented as voluntary, and penalties for refusing it.
• State-imposed forced labour in the production of electronics components and their inputs, which is the subject of section 307 of the US Tariff Act of 1930 and of the Uyghur Forced Labor Prevention Act, and which reaches the group through hardware and terminals rather than through any direct purchase.
• Child labour and forced labour in the artisanal mining of cobalt, tantalum, tin, tungsten and gold. The group has its registered office in the Democratic Republic of the Congo, where this risk is documented in its own country and in the region, and the honest position is to name it rather than to place it abroad.
• Subcontracting chains in construction that add a tier for each trade, so that the workers on site are engaged by a party the group has never contracted with.
• Guarding and cleaning contracts awarded on price, where the margin is taken out of wages and the workforce is supplied by brokers.

The group prohibits forced labour, bonded labour, indentured labour, prison labour imposed as a means of coercion, human trafficking and child labour, in its own operations and in the supply chains that serve them. The prohibition is expressed by reference to the ILO instruments rather than to a definition of its own, so that it means the same thing in each country the group operates in.

• Conventions No. 29 and No. 105 on forced labour and the Protocol of 2014, and Conventions No. 138 and No. 182 on the minimum age and on the worst forms of child labour, are the reference standards.
• The employer pays principle: no worker pays a fee to obtain work with the group or with a supplier acting for it, at any stage of recruitment, and fees already paid are reimbursed rather than merely prohibited for the future.
• No identity document is retained, no deposit is taken, and no worker is prevented from leaving their employment on reasonable notice.
• Every worker has a written contract in a language they understand, stating pay, hours and the terms of accommodation where accommodation is provided.
• Freedom of association and the right to collective bargaining are respected, and where local law restricts them the group does not use that restriction as a reason to obstruct workers organising.
• Any person working under the supervision or direction of a contractor, subcontractor or supplier of the group may use the reporting channel in the whistleblowing policy, on the same protection against retaliation as an employee.

Due diligence here means the process described by the UN Guiding Principles and by the OECD Guidance: identify the risk, act on it, track whether the action worked, and account for it publicly. The group is at the beginning of that process and says so.

• Mapping of first-tier suppliers by category, country of delivery and country of manufacture where it is known, starting with the four high-exposure categories rather than with the whole vendor list.
• Risk scoring by category and country, using the risk indicators set out above and the OECD guidance on minerals from conflict-affected and high-risk areas, rather than a supplier self-declaration alone.
• The contractual terms required of suppliers below, imposed on new contracts and on renewals in the high-exposure categories first.
• A grievance route that reaches workers rather than only counterparties: the whistleblowing channel is open to the workforce of contractors, subcontractors and suppliers, and this statement is the notice of it.
• Escalation and remediation as the first response to a finding, with termination reserved for a supplier that refuses to remediate — cutting a contract on discovery leaves the worker in the same place with one buyer fewer to answer to.

The following terms are required in new supplier contracts and at renewal, starting with the categories marked high in the table above. They are drafted as obligations with consequences rather than as declarations of principle, because a clause that cannot be breached cannot be enforced.

• Prohibition of forced, bonded, indentured and child labour and of human trafficking, defined by reference to the ILO conventions listed above.
• The employer pays principle, with an express obligation to reimburse any recruitment fee already borne by a worker, whoever collected it.
• Prohibition of retaining identity documents, of charging deposits, and of restricting the freedom of movement of workers.
• A written contract for every worker in a language they understand, wages paid directly to the worker on time and without unlawful deduction, and working time within the applicable legal limits.
• Notification to the group of any credible allegation of forced or child labour in the operations of the supplier or its own suppliers, within five working days of the supplier becoming aware of it.
• A right of information about lower-tier suppliers for the categories marked high, and flow-down of these terms to subcontractors, with the supplier answerable for their compliance.
• A right of inspection, including unannounced inspection and access to workers, exercisable by the group or by a party it appoints. The group states plainly that it has not yet exercised this right.
• An obligation to co-operate in remediation, including reimbursement of fees, repayment of withheld wages and repatriation where a worker asks for it.
• Termination for a supplier that refuses to remediate or that conceals a finding, and no clause of a group contract restricts a worker or a supplier employee from making a report.

Coverage is not complete. Contracts signed before this clause set existed remain in force on their original terms and are being renegotiated at renewal. The group publishes no percentage of covered spend, because it has not measured one, and a figure produced for a statement rather than by a measurement is worth nothing to the reader.

The order of operations matters, and it puts the worker first. On a credible finding, the group acts to remove the immediate harm — recovery of retained documents, reimbursement of recruitment fees and payment of withheld wages by the party that owes them, and safe accommodation or repatriation where the worker asks for it. Only then does it deal with the commercial relationship.

A supplier that co-operates is kept under a corrective plan with dates, because ending the contract ends the leverage. A supplier that conceals a case or refuses to remediate is terminated. Where the facts suggest an offence, they are reported to the competent authority of the jurisdiction concerned; nothing in a group contract prevents that report, and confidentiality clauses are not applied to it.

Training is directed at the people who can actually see the risk: the staff who select suppliers, negotiate service contracts, receive deliveries, supervise sites, and hire. General awareness for everyone else is worth less than a buyer who knows what a recruitment fee looks like in a quotation.

• The ILO indicators of forced labour, and how each one appears in a quotation, a site visit or a payroll rather than in a definition.
• Recruitment through brokers: the questions to ask, the documents to request, and the answers that should stop a contract.
• The clause set required of suppliers, what it obliges the supplier to do, and how a breach is escalated.
• How to make a report, and the protection that attaches to it under the whistleblowing policy.

This training is being built and has not yet been delivered across the group. No completion rate is published here, for the same reason no audit result is: the figure does not exist yet.

Section 54(5)(e) of the UK Act asks an organisation to measure its effectiveness against appropriate performance indicators, and section 16(1)(e) of the Australian Act asks how the entity assesses the effectiveness of its actions. The indicators the group will report on are set out below with their current state. None has a baseline yet, and inventing one would defeat the purpose of the requirement.

• Complete the mapping of first-tier suppliers in the four high-exposure categories, and record the country of manufacture where the supplier will state it.
• Carry out the first risk assessment on that mapping, and publish what it found in the next statement, including the categories where the group could not establish the facts.
• Extend the clause set required of suppliers to contracts predating it, at renewal or by amendment.
• Deliver the training described above to procurement, site supervision and hiring staff, and record completion.
• Establish the baseline for each indicator listed above.
• Obtain board approval and a director signature, so that this text becomes a statement within the meaning of section 54(6), and republish it for each financial year within six months of its close; where an entity of the group falls within the Australian Act, file the statement with the register under section 14.