Modern Slavery statement
Overview
Modern Slavery is a crime and a violation of fundamental human rights. It covers four activities:→ Slavery - Exercising powers of ownership over a person,
→ Servitude - The obligation to provide services is imposed by the use of coercion,
→ Forced or compulsory labour - Work or services are exacted from a person under the
menace of any penalty and for which the person has not offered themselves voluntarily,
→ Human trafficking - Arranging or facilitating the travel of another person with a view to their exploitation.
In addition, the definition of "modern slavery" in the Modern Slavery Act 2018 (Modern Slavery Act) includes:
→ Child labour: children below 12 years of age undertaking at least one hour of economic activity or 28 hours of domestic work or children aged between 12 and 14 years of age undertaking at least 14 hours of economic activity or 42 hours of domestic work and economic activity combined.
→ Debt bondage: a person's pledge of labour or services as security for the repayment of a debt or other obligation, but there is no hope of repaying the debt. The services required to repay the debt, or the time in which to repay the debt, may be undefined.
→ other slavery-like practices.
Purpose
3Gem Media Group takes its compliance with statutory obligations seriously. As noted above, this document is directed to assisting 3Gem Media Group to comply with its obligations under the Modern Slavery Act. 3Gem Media Group has a zero-tolerance approach to Modern Slavery within its business and supply chain and is committed to acting ethically and with integrity in all its business dealings and relationships and to Implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place in its own business or in any of its supply chain.
Policy statement
Modern slavery is a complex and multi-faceted crime. At a basic level, of course preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense. The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do so. With this in mind, we need to pay particular attention to:
→ our supply chain;
→ any outsourced activities, particularly to jurisdictions that may not have adequate safeguards;
→ cleaning and catering suppliers; and
→ corporate hospitality.
Responsibility Allocation
Everyone within the Company shall be responsible and must observe this policy and be aware that turning a blind eye is unacceptable and not an option.
i. The CompanyWe will:
→ maintain policies and procedures aimed at preventing exploitation and human trafficking, and protecting our workforce and reputation
→ be clear about our recruitment policy (see Recruitment)
→ check our supply chains (see Supply chains)
→ have in place an open and transparent grievance process for all staff
→ seek to raise awareness so that our colleagues know what we are doing to promote
appropriate welfare practices
→ make a clear statement that we take our responsibilities to our employees and our clients seriously (see Anti-slavery statement)
ii. Line Managers/ Heads of Departments/Units
Managers will:
→ listen and be approachable to colleagues
→ remain alert to indicators of slavery
→ raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do.
iii. Employees/ Colleagues
We all have responsibilities under this policy. Whatever your role or level of seniority, you must:→ keep your eyes and ears open—if you suspect someone is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery)
→ follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated.
→ tell us if you think there is more we can do to prevent people from being exploited
The Risks
The principal areas of risk we face, related to slavery and human trafficking, include:→ some components of our supply chain
→ temporary service staff
Our procedures
Anti-slavery statementWe make a clear statement that we take our responsibilities to our employees, people working within our supply chain and our clients seriously.
Supply Chains
We check our supply chain to reduce the potential for slavery and human trafficking.
→ We tell the companies we do business with that we are not prepared to accept any form of exploitation.
→ All our significant supplier contracts, for industries considered high risk, should contain an anti-slavery clause. This clause will ask suppliers and their employees to commit not to engage in slavery or human trafficking and to diligence their own supply chain.
→ We work to account for our supply processes—we know who is providing goods and services to us and we have mechanisms and processes in place to check, including reviewing our significant suppliers’ identity and level of risk in this area, and making efforts to confirm their adherence to anti-slavery measures in their businesses.
Recruitment
Using agencies
Our HR department follows firm policy and only uses agreed specified reputable recruitment agencies.
→ To reduce the potential for slavery and human trafficking, we diligence recruitment agencies before adding them to our list of approved agencies. This includes:
(i) investigating reputation
(ii) asking the agency to provide assurances that the appropriate checks have been made on the person they are supplying.
→ We keep agents on the list under regular review.
General recruitment
We verify staff are legally able to work in the relevant office.
→ We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
If, through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures.
Identifying slavery
There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim.
→ The person is not in possession of their own passport, identification or travel documents.
→ The person is acting as though they are being instructed or coached by someone else.
→ They allow others to speak for them when spoken to directly.
→ They are dropped off and collected from work.
→ The person is withdrawn or they appear frightened.
→ The person does not seem to be able to contact friends or family freely.
→ The person has limited social interaction or contact with people outside their immediate environment.
Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, report it.
Reporting slavery
Talking to someone about your concerns may stop someone else from being exploited or abused. If you think that someone is in immediate danger, call the police. Otherwise, you should discuss your concerns with a business lead or Executive Director who will decide a course of action and provide any further advice. Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with the business lead or Executive Director before taking any further action.
Training
We provide specific training to those staff members who are involved in managing recruitment and our supply chains.
→ More general awareness training is provided to all staff through induction training sessions, and e.g. regular electronic refresher alerts.
Monitoring our procedures
We will review our Anti-slavery policy regularly. We will provide information and/or training on any changes we makeCrisis management and business continuity
When confronted with a potential Modern Slavery incident or risk, the relevant Officer should consider whether the incident or risk may give rise to obligations under 3Gem Media GroupS’s crisis management and business continuity plans.
Breaches of the policy
→ The Ethical Standards Officer will arrange an investigation into reported breaches of this Policy. The investigation may utilise internal and external resources considered necessary. The outcome of the investigation included recommended actions will be reported to the Executive Leadership Team with material matters reported to the Board of Directors.
→ Any employee who breaches this Policy by engaging in or conspiring to engage in any Modern Slavery conduct will face disciplinary action. This could, in the most severe circumstances include immediate dismissal for misconduct or gross misconduct and, if warranted, legal proceedings may be brought against the employee.
→ 3Gem Media Group may terminate its relationship with individuals, organizations and suppliers working on its behalf or engaged by it if they breach this Policy.
