Introduction
This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 December 2022
Organisational structure
This statement applies to WhittleMedia Ltd (referred to in this statement as ‘the Organisation’).
WhittleMedia Limited has business operations in the United Kingdom. We operate in the events and experiential sector. The nature of our supply chains is as follows: We work with a number of key direct suppliers who provide us with goods and services such as equipment and staffing for events, and services, such as outsourced business processes, IT software and marketing services.
For more information about the Company, please visit our website: www.experience12.com.
Definitions
The Organisation considers that modern slavery encompasses:
- human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse of the threat of abuse
- being dehumanised, treated as a commodity or being bought or sold as property
- being physically constrained or to have restriction placed on freedom of movement.
Commitment
The Organisation acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.
The Organisation understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.
The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
No labour provided to the Organisation in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Organisation strictly adheres to the standards required in relation to its responsibilities under relevant employment legislation in the UK.
Potential exposure
The Organisation considers its main exposure to the risk of slavery and human trafficking to exist in the supply of merchandise or materials from non UK or EU suppliers through the supply chain.
In general, the Organisation considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
Steps
The Organisation carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.
The Organisation has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.
In accordance with section 54(4) of the Modern Slavery Act 2015, the Organisation has taken the following steps to ensure that modern slavery is not taking place:
Recruitment and selection policy – We conduct checks on all prospective employees to verify that they are eligible to work in the UK. Certain roles require a Disclosure and Barring Service (DBS) check where employees may be working with vulnerable people.
Supplier code of conduct – We operate this policy to ensure our suppliers operate in full compliance with the laws, rules and regulations of the countries in which they operate, and to seek similar commitments across their own supply chain.
Whistleblowing policy – We operate this policy so that employees are able to raise concerns about how staff are being treated or practices within our business or our supply chains without fear of reprisal
Staff code of conduct – We are committed to the fair treatment of all staff. Our staff code of conduct reflects our core values and expected behaviours. The code of conduct makes it clear that we have a zero-tolerance approach to modern slavery.
Safeguarding policy – This policy highlights the potential risks of modern slavery and human trafficking, including how to identify signs of exploitation and how to report concerns.
Due Diligence
We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will seek to terminate our relationship with that supplier immediately.
Anti Slavery Compliance Officer
The Organisation has a Slavery Compliance Officer, Chris Whittle to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.
This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.