Slavery and human trafficking statement
Slavery and human trafficking statement
Slavery and human trafficking statement for the financial year ending 30 June 2024, approved by the Board of Directors on 30 June 2023
Slavery and human trafficking statement for the financial year ending 30 June 2024, approved by the Board of Directors on 30 June 2023
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 ('Act') and is the slavery and human trafficking statement for the financial year ended 30 June 2023 for Two Degrees Below.
INTRODUCTION Two Degrees Below recognises the importance of combating slavery and human trafficking. We do not tolerate modern slavery or human trafficking in our organisation or in our supply chain. This statement sets out the steps that Two Degrees Below is committed to taking across the business to eliminate, as far as possible, the risk of modern slavery and human trafficking taking place.
For the purposes of this statement, slavery and human trafficking are based on the definitions set out in the Act.
OUR BUSINESS Two Degrees Below is a creative communications agency, spanning design, content, event production, film, digital and internal communications. Headquartered in Leeds the business has 10 employees and operates primarily in the UK. When carrying out due diligence for any new businesses we acquire, we carry out detailed due diligence which includes analysis to ensure they meet our minimum standards of compliance with the values and standards set out in this document.
OUR SUPPLY CHAINS Given the nature of our businesses, we do not have an extensive supply chain network. Our supply chains include (but are not limited to): comms consultants, production companies, information technology providers (software and hardware) and software developers, professional services, insurance and benefits providers, recruitment agencies, office facilities and maintenance service providers, and film production, market research and other marketing services providers. During the year to 30 June 2023, we were not made aware of, nor did we discover, any issues relating to modern slavery in our supply chain.
OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The business does not operate in an industry where modern slavery is prevalent, but we acknowledge that we may operate (by either having offices or clients or suppliers) in countries where modern slavery exists. Our internal Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
RISK ASSESSMENT AND DUE DILIGENCE PROCESSES We continue to view our industry and the majority of our suppliers as low-risk. Where any higher-risk areas are identified, we will seek to mitigate the risk of modern slavery occurring by building a more detailed review of potentially high-risk suppliers into our internal process by:
▪ gathering further information of the potentially high-risk services;
▪ obtaining relevant contractual terms; and
▪ holding discussions with the relevant department lead to see the steps taken by them in vetting the supplier, for example whether they have visited the supplier offices or have any other reasons for concern.
We will report at least once each year on our top five suppliers as well as any other suppliers they have identified as being potentially high risk. We follow a supplier approval process, when onboarding suppliers, to obtain detailed information about them and their processes to ensure that we work with suppliers who do not tolerate unethical behaviours, pay a living wage and have appropriate diversity of ownership. Before entering into a contract with a new supplier it must confirm it meets certain minimum standards that we expect of them. This process is being enhanced and expanded during 2023.
RESPONSIBILITY FOR COMPLIANCE The responsibility for all necessary activities to ensure Two Degrees Below's compliance with the values and standards set out in this statement will be co-ordinated across the businesses legal, human resources, finance, and operations functions.
RECRUITMENT We are an equal opportunities employer and pay a fair living wage in all jurisdictions that we operate in. All contracts of employment are drafted in accordance with the highest standards of local law and are compliant with human rights standards. We are confident that there is no risk of slavery or human trafficking in the employment or engagement of employees across the business, but we remain vigilant.
TRAINING AND AWARENESS To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we are committed to: providing appropriate training to relevant staff, including through induction programmes and communication of the Modern Slavery Policy communicating our zero-tolerance approach to modern slavery to relevant suppliers, contractors, and business partners at the outset of our business relationship with them, and where appropriate thereafter. We are also renewing our internal training in 2023 to ensure that we have appropriate levels of awareness among employees of issues related to slavery and human trafficking including ensuring the mechanisms available to our workforce are sufficiently known about, trusted and accessible. Our processes will always protect individuals who come forward from being victimised further and provide access to counselling and support.
FURTHER STEPS We will review the effectiveness of the steps we are taking to ensure that there is no slavery or human trafficking in our supply chains and that any new mechanisms employed are adequate and fit for purpose. Following the improvements that we have committed to this year, we aim to monitor and, where necessary, improve our policies, procedures and systems on a continual basis.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the businesses slavery and human trafficking statement for the financial year ending 30 June 2023.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 ('Act') and is the slavery and human trafficking statement for the financial year ended 30 June 2023 for Two Degrees Below.
INTRODUCTION Two Degrees Below recognises the importance of combating slavery and human trafficking. We do not tolerate modern slavery or human trafficking in our organisation or in our supply chain. This statement sets out the steps that Two Degrees Below is committed to taking across the business to eliminate, as far as possible, the risk of modern slavery and human trafficking taking place.
For the purposes of this statement, slavery and human trafficking are based on the definitions set out in the Act.
OUR BUSINESS Two Degrees Below is a creative communications agency, spanning design, content, event production, film, digital and internal communications. Headquartered in Leeds the business has 10 employees and operates primarily in the UK. When carrying out due diligence for any new businesses we acquire, we carry out detailed due diligence which includes analysis to ensure they meet our minimum standards of compliance with the values and standards set out in this document.
OUR SUPPLY CHAINS Given the nature of our businesses, we do not have an extensive supply chain network. Our supply chains include (but are not limited to): comms consultants, production companies, information technology providers (software and hardware) and software developers, professional services, insurance and benefits providers, recruitment agencies, office facilities and maintenance service providers, and film production, market research and other marketing services providers. During the year to 30 June 2023, we were not made aware of, nor did we discover, any issues relating to modern slavery in our supply chain.
OUR POLICY ON SLAVERY AND HUMAN TRAFFICKING We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. The business does not operate in an industry where modern slavery is prevalent, but we acknowledge that we may operate (by either having offices or clients or suppliers) in countries where modern slavery exists. Our internal Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
RISK ASSESSMENT AND DUE DILIGENCE PROCESSES We continue to view our industry and the majority of our suppliers as low-risk. Where any higher-risk areas are identified, we will seek to mitigate the risk of modern slavery occurring by building a more detailed review of potentially high-risk suppliers into our internal process by:
▪ gathering further information of the potentially high-risk services;
▪ obtaining relevant contractual terms; and
▪ holding discussions with the relevant department lead to see the steps taken by them in vetting the supplier, for example whether they have visited the supplier offices or have any other reasons for concern.
We will report at least once each year on our top five suppliers as well as any other suppliers they have identified as being potentially high risk. We follow a supplier approval process, when onboarding suppliers, to obtain detailed information about them and their processes to ensure that we work with suppliers who do not tolerate unethical behaviours, pay a living wage and have appropriate diversity of ownership. Before entering into a contract with a new supplier it must confirm it meets certain minimum standards that we expect of them. This process is being enhanced and expanded during 2023.
RESPONSIBILITY FOR COMPLIANCE The responsibility for all necessary activities to ensure Two Degrees Below's compliance with the values and standards set out in this statement will be co-ordinated across the businesses legal, human resources, finance, and operations functions.
RECRUITMENT We are an equal opportunities employer and pay a fair living wage in all jurisdictions that we operate in. All contracts of employment are drafted in accordance with the highest standards of local law and are compliant with human rights standards. We are confident that there is no risk of slavery or human trafficking in the employment or engagement of employees across the business, but we remain vigilant.
TRAINING AND AWARENESS To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we are committed to: providing appropriate training to relevant staff, including through induction programmes and communication of the Modern Slavery Policy communicating our zero-tolerance approach to modern slavery to relevant suppliers, contractors, and business partners at the outset of our business relationship with them, and where appropriate thereafter. We are also renewing our internal training in 2023 to ensure that we have appropriate levels of awareness among employees of issues related to slavery and human trafficking including ensuring the mechanisms available to our workforce are sufficiently known about, trusted and accessible. Our processes will always protect individuals who come forward from being victimised further and provide access to counselling and support.
FURTHER STEPS We will review the effectiveness of the steps we are taking to ensure that there is no slavery or human trafficking in our supply chains and that any new mechanisms employed are adequate and fit for purpose. Following the improvements that we have committed to this year, we aim to monitor and, where necessary, improve our policies, procedures and systems on a continual basis.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the businesses slavery and human trafficking statement for the financial year ending 30 June 2023.
Version: 1
Date: August 2023
Author: Joe Yates
Owner: Clare Taylor
Last Reviewed: August 2023
Next Review: July 2024
Next date for annual issue: August 2024