Modern slavery policy

Policy Details

Introduction

This statement sets out Manifest’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.

As part of PR, media and communications, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Manifest:

  • Manifest is an integrated brand communications agency

Countries of operation and supply

The organisation currently operates in the following countries:

  • United Kingdom

The following is the process by which the company assesses whether or not particular activities or countries are high-risk in relation to slavery or human trafficking:

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows

  • Policies: People team with Senior Management team
  • Risk assessments: Annually with Senior Management team and external specialist support
  • Investigations/due diligence: People team with Senior Management Team
  • Training: This policy and supporting information

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations

  • Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can use our confidential complete our confidential disclosure form.
  • Employee code of conduct The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Recruitment workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include

  • evaluating the modern slavery and human trafficking risks of new suppliers
  • reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
  • conducting supplier audits or assessments through [the organisation’s own staff/third party auditor], which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans if needed;
  • participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking;
  • using SEDEX where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and

Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is [select the relevant KPIs from the list below]:

  • requiring staff working in UK and HR professionals to have completed training on modern slavery by 01/01/2020
  • reviewing its existing supply chains expected to be completed by 01/01/2020, whereby the organisation evaluates all existing suppliers.

Training

The organisation requires all staff working in HR within the organisation to complete training on modern slavery as a module within the organisation’s wider human rights/ethics/ethical trade training programme.

The organisation requires all staff to sign up to one training session being run by 01/01/2020

The organisation’s modern slavery training covers

  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
  • how to identify the signs of slavery and human trafficking;
  • what initial steps should be taken if slavery or human trafficking is suspected;
  • how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
  • what external help is available, for example through theModern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative;
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
  • what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

Awareness-raising programme

As well as training staff, the organisation has raised awareness of modern slavery issues by implementing this policy.

The policy explains to staff [select the relevant issues from the list below]:

  • the basic principles of the Modern Slavery Act 2015;
  • how employers can identify and prevent slavery and human trafficking;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.
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