Modern Slavery Policy -  Statement 2024

This policy statement ensures that CTI Digital Limited (We, Our) and each of its group companies, 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 current financial year ending 28th February 2025.

1. Structure of the organisation

We employ (and contract, where relevant) c.200 people with our core operations in the United Kingdom. We work with various partners and suppliers, across a range of sectors.

2. Policies

As an employer, we are committed to ensuring that we act and treat our employees, contractors, partners and suppliers ethically, fairly and with respect.

All CTI Digital Employees and contractors are required to abide by all company policies. We have a number of policies in place to ensure that our business is being conducted in an ethical and transparent manner, and we encourage our team to come forward with any concerns without fear of retaliation when they see an action they view as unethical or unfair so we may take appropriate corrective action.

Our team is treated fairly and all employees are paid at least the Real 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 is trained 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 mitigate risks within our group 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 the Real Living Wage or above;
    We periodically conduct an anonymous and confidential staff survey, in which we elicit views about pay, benefits and wellbeing, 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 company policies, business principles and ethical values, as well as any relevant laws and professional codes of conduct applicable to us; and
    We train new and existing employees to help them understand and identify modern slavery and its impact. 


Supply Chain

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 we will terminate relationships with any supplier we believe may be likely to breach the Act;
    Require contractors to agree to comply with all companies policies; and
    We ensure a commitment to the Act when contracting with third-party supplier terms.


4. Training

We are committed to raising awareness and understanding of the Act amongst all of our employees, suppliers and contractors.

All new employees undergo mandatory training via our Policy Management Hub and we conduct 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.