Modern Slavery Policy
Purpose and scope
The purpose of this Modern Slavery Policy is to communicate See Media Ltd’s commitment to delivering a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”).
Modern Slavery Policy Statement
Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement defines See Media’s commitment to ensuring that human trafficking, slavery, forced labour and harmful child labour will never exist within its own business.
In addition, See Media commits to never knowingly using or procuring unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilise child labour or forced labour.
Definitions
Human trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation.
Forced labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty.
Harmful child labour: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development.
Rationale
See Media has appointed its Managing Director as its senior compliance officer and will take appropriate steps to ensure not only its own compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by its “Suppliers”).
All Suppliers are therefore required to adhere to the following:
- Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty;
- Will ensure that the overall terms of employment are voluntary;
- Will comply with the minimum age requirements prescribed by applicable laws
- Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements;
- Will abide by applicable law concerning the maximum hours of daily labour;
- Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK
Audits
Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of See Media. See Media may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit.
Reporting
Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting See Media’s Managing Director.
Consequences
See Media takes any breach of this Policy extremely seriously.
Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with See Media terminated immediately, without compensation.
If a Supplier to See Media is found in violation of this policy, See Media will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti- Slavery and Human Trafficking Officer shall determine to be necessary to address the violation and seek to prevent its recurrence.
Policy Management
The policy applies to all staff within See Media Ltd (the Company), including employees and other workers, such as agency workers, temporary workers and contractors. All staff are expected to put this policy into practice.
A copy of this policy is distributed to all employees and is made available to other workers on their engagement. Job seekers and applicants are sent a copy of the policy on request. In addition, all employees have received briefing on this policy and the induction process for new employees includes a briefing on this policy.
Any questions about the policy should be directed to the Managing Director.
The policy is regularly reviewed and may be amended at any time.
Effective Date
This policy is effective from September 2023
Next Review: September 2024
Stuart Macdonald, Managing Director, See Media