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Policy 11

Modern Slavery & Ethical Supply Chain

“We oppose slavery, forced labour, trafficking and exploitation, wherever it might hide in a supply chain.”

A small UK creative studio has a different risk profile from a global manufacturer, but risks can still sit behind electronics, clothing, merchandise, printing, facilities and outsourced services. We keep proportionate controls in place.

  • Version 1.0
  • Effective October 2026
  • Next review October 2027

At a glance

The short version.

1

Voluntary, not required

We’re below the £36m threshold for a statutory statement, but we keep internal controls and publish this policy voluntarily.

2

Risk-based checks

Higher-risk or strategic suppliers may be asked for policies, certifications and commitments.

3

Workers first

If concerns arise, we choose the response that doesn’t leave affected workers worse off.

£36mturnover threshold for a statutory statement
Section 54Modern Slavery Act 2015

In practice

What we commit to.

  • No forced, bonded or trafficked labour
  • No unlawful child labour
  • No retention of passports or ID documents
  • Lawful pay and safe working conditions
  • Freedom to raise concerns without retaliation
  • No labour through worker-paid recruitment fees or coercion
  • Avoid bureaucracy that shuts out responsible small local suppliers

The detail

Everything else.

The key parts of the policy, in plain English. The downloadable PDF is the full, controlled version.

Who it covers

Employees, workers, freelancers, subcontractors, technology and equipment suppliers, printers and merchandise suppliers, facilities, cleaning, catering and event suppliers, and any outsourced production.

Warning signs

Low-cost labour-intensive products, opaque subcontracting, recruitment fees, unusually low prices, withheld documents, or a supplier unwilling to answer basic questions about labour practices.

Responding to concerns

We investigate proportionately. Responses range from clarification and corrective action to suspension, termination or reporting to the authorities.

Training and review

People involved in purchasing understand the warning signs. The directors review every year whether we meet any reporting threshold and whether a public statement is needed.

Laws and guidance this policy follows
  • Modern Slavery Act 2015, section 54
  • Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015
  • Government Supplier Code of Conduct

The full document

Modern Slavery & Ethical Supply Chain Policy

Version 1.0 · Effective October 2026 · Owner: Managing Directors / Operations

Download PDF ↓

Questions about this policy?

If you have a concern about anyone in our supply chain, please tell us.

Email us →