Modern Slavery and Human Trafficking - Statement 2022
This policy statement ensures that CTI Digital (We, Our) Limited complies with the Modern Slavery Act 2015 (the Act).
We recognise our obligation to prevent slavery and human trafficking and are committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain.
We pride ourselves on our reputation and integrity. We will endeavour to take all possible actions to ensure that there is no slavery or human trafficking within our business or supply chains.
This statement is approved by our ESG Committee and Board of Directors and made according to Section 54 of the Act and constitutes our Modern Slavery and Human Trafficking Statement.
This statement applies to the financial year ending 28th February 2022.
1. Structure of the organisation
We employ over 200 people with our core operations in the United Kingdom. We work with various partners and suppliers, including property, professional services, and soft water vendors.
Our ESG framework provides an overarching approach to creating policies to support our social responsibility, encouraging our team to come forward with any concerns without fear of retaliation so we may take appropriate corrective action.
Our associated policies include the following:
- Disciplinary issues
- Code of Conduct
- Diversity & Inclusion
Our team is treated fairly and paid above the national living wage. No one is required to work more than the number of hours permitted under UK employment law, and our regular working hours will not exceed 48 hours per week unless the employee agrees in writing.
Our team are training to identify and report signs of human trafficking, forced labour, servitude and slavery.
We will continue to review our policies and procedures to ensure our employees have access to any additional information and support that they may require regarding human trafficking, forced labour, servitude and slavery.
3. Due diligence, risk and compliance:
We mitigate risks within our company and supply chain through the following measures:
We apply high standards in the recruitment, selection and employment of our people to ensure that:
- All legal obligations are complied with in the recruitment and induction process;
- We recruit, promote and develop our people on the grounds of merit and capability;
- We pay at least national living wage or above;
- We periodically conduct an anonymous and confidential staff survey, in which we elicit views about pay, benefits, working hours and conditions, as well as leadership, values and culture;
- We encourage the reporting of concerns and provide appropriate protection for whistle-blowers;
- Our team are required to comply with our business principles, ethical values and sustainable procurement policy, as well as any relevant laws and professional codes of conduct applicable to us;
- We will train new and existing employees to help them understand and identify modern slavery and its impact.
In selecting suppliers we:
- Build long-term relationships with all key suppliers and highlight to them our requirements for appropriate business behaviour and our commitments to the Act
- Periodically review suppliers to identify those with more risk by nature or geography of their operations.
- Work with such suppliers to understand their policies on Modern Slavery and terminate relationships with any supplier we believe may be likely to breach the Act.
- Require suppliers to sign our supplier terms and conditions, which includes a commitment to the Act.
- We ensure a commitment to the Act when contracting with third-party supplier terms.
4. Effectiveness and KPIs
Our full-time in-house dedicated Compliance Officer undertakes regular internal audits and provides feedback on performance. Our ESG committee, chaired by our Chief Operating Officer, reviews the effectiveness of policies quarterly.
Modern Slavery and Human Trafficking have achieved 100% compliance in all categories over the last 12-month period.
We are committed to raising awareness and understanding of the Modern Slavery Act amongst all of our employees.
Our Policy Management Hub ensures compliance with mandatory induction and annual refresher training. The training covers the principle of the Modern Slavery Act 2015, how to identify potential concerns and how best to raise them, and requirements for suppliers.