Modern Slavery statement

This document is published (and updated annually) in accordance with Section 54 of the Modern Slavery Act 2015.

  1. Definition of modern slavery

1.1               Modern slavery” is a term which covers slavery (where ownership is exercised over a person); servitude (which involves the obligation to provide services imposed by coercion); forced or compulsory labour (which involves work or service exacted from any person under the menace of a penalty and for which the person has not offered himself voluntarily); and human trafficking (which concerns arranging or facilitating the travel of another with a view to exploiting them, even where the person consents to the travel).

1.2               We will ensure that we will comply with the Modern Slavery Act 2015 and are putting strict measures in place to ensure that modern slavery is not part of any of our business operations. This includes our supply chains, goods and services. This statement sets out the steps we are taking to continually develop our procedures and to check our compliance.

1.3               This statement covers our financial year ending 31 December 2023.

2. Overview

2.1               An overview of our organisational structure, key business activities and supply chains is as follows:

·        The sector(s) the business operates in and the nature of the activities

·        Your business operating model (eg direct sales, through trusted partners, franchise etc)

·        The organisation structure (top level) and group relationships (ie any associated companies, group structures etc)

·        The make-up and complexity of the supply chains – where are your suppliers based? Which are the key value contracts? What are the key risk areas? Include an outline of the make-up and complexity of the supply chain, including the countries you source your goods or services from, including high risk countries where modern forms of slavery are prevalent; how you source and select suppliers (eg via tender/audits etc)

·        Relationships with suppliers and others, including trade unions and other bodies representing workers.

2.2               We work closely with our main suppliers and customers; with our employees and their representatives to ensure the highest level of compliance with industry standards and ethical trading initiatives,

3. Responsibilities

·        The Board of Directors of Speak Media is responsible for overseeing our efforts to help to eliminate modern slavery and for monitoring progress against the KPIs contained in this document.

·        Our managers are responsible for ensuring that all recruitment and terms and conditions of employment comply with statutory requirements, and that any agencies used are appropriately checked and commit to ethical standards.

·        Managers are responsible for upholding our “core values” and for ensuring that employees who work for them also behave in accordance with these.

4. Documentation

4.1              We have the following policies in place for employees:

·        Business ethics policy

·        Grievance procedure

·        Equal opportunity policy

·        Whistleblowing policy

4.2               These are referenced in our employee handbook and copies are available on our intranet. All policies are updated on an annual basis, and we consult with managers and all employees prior to updating them.

4.3               Employees are reminded of the policies from time and time and notified of any updates. 

5. Actions we are taking

5.1               We have taken the following actions as part of our drive to eliminate modern slavery: 

5.2             Employees

5.2.1           We have a recruitment and selection policy to assist compliance with equal opportunity.

5.2.2         All new employees are recruited directly.  Right to work checks are conducted prior to joining, and we check with all new recruits that they have not been required to pay any fees to gain work with us, and inform them of the procedures that should be followed should they wish to leave our employment.  In addition, we check that their passports have not been withheld and that they have not been required to sign any agreements with any third parties in respect of our offer of employment.

5.3             Agency workers

5.3.1           We only use agency workers sparingly, for temporary placements and holiday/sickness cover.

5.3.2           We will ensure that any recruitment agencies we use have strict compliance to the Modern Slavery Act and require written confirmation from them that no agency worker is being exploited as part of any slavery or human trafficking.

6. Due diligence, monitoring and auditing processes

6.1               All suppliers are issued with our Code of Conduct and are required to sign and return a commitment to ensuring that they take appropriate steps to ensure that their businesses and supply chains are free from modern slavery. prior to any orders being placed with them.  

7. Penalties for breach

7.1               If a supplier is found to be involved in any form of modern slavery, its contract will be terminated either immediately or on its due renewal date, depending on the severity of the breach and we may also  report any suspicions of criminal activity to the police.

7.2               If the breach is a minor one, we commit to helping that supplier by providing guidance and support for the affected workers.

7.3               If it is established that any employee has acted in breach of any of our policies, or is aware of, has condoned or failed to report any suspicion of modern slavery within our business or supply chains, he/she will be subject to our disciplinary procedure.

8. Training

8.1               We will provide suitable training for all employees to ensure that they are aware of this Statement and can be vigilant in identifying and reporting any concerns they have.

8.2               Employees and managers are informed of any updates to our policies via email.

Approved by the Board on 1 Jan 2023