Modern slavery.

This policy applies to all persons working for Digi2al Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers. Digi2al Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

 

Key principles

Modern Slavery and Human Trafficking Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights. 

Procedures

Digi2al Ltd is a company that expects everyone working with us or on our behalf to support and uphold the defined measures to safeguard against modern slavery.  The following procedures are designed to:

  1. Identify and assess potential risk areas in our business and supply chains.

  2. Reduce the risk of slavery and human trafficking occurring in our business and supply chains.

  3. Monitor potential risk areas in our business and supply chains.

  4. Provide adequate protection for whistleblowers.

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains; 

  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for Digi2al or on our behalf; 

  • Expect our suppliers to have suitable anti-slavery and human trafficking policies and processes in place within their own businesses and to cascade those policies to their own suppliers;

  • Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy;  

  • Digi2al are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain;  

  • Digi2al take a risk based approach to our contracting processes and keep them under review; 

  • Digi2al assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties; 

  • Using our risked based approach Digi2al will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking; 

  • Consistent with our risk based approach we may require: 

    • employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct; 

    • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code   As part of our ongoing risk assessment and due diligence processes Digi2al will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct;  

  • Whistleblowers are protected through our confidential whistleblowing policy;

  • If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.