Anti-slavery and human trafficking policy

Introduction
This modern slavery and human trafficking statement is made by Proctor and Stevenson Ltd (‘Proctors’) in accordance with section 54 of the Modern Slavery Act 2015. It describes the steps we have taken to identify, prevent and address the risk of modern slavery in our operations and supply chains.

Our organisation, business and supply chains
Proctor and Stevenson Ltd (‘Proctors’) is a marketing and digital communications agency based in Bristol, United Kingdom. We provide creative, strategy and technology services to clients in the professional services, manufacturing and public sectors internationally.

Our supply chains include, but are not limited to, marketing technology providers, software and cloud services, office equipment and supplies, print and production, facilities management and professional services.  

Our supply chain is primarily based in the United Kingdom and Europe, with some technology and specialist services sourced globally.

Governance and responsibility
RESPONSIBILITY FOR THE POLICY

1. The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

2. The HR manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure consistency with the Modern Slavery Act 2015.

3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

4. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the HR manager.

COMPLIANCE WITH THE POLICY

1. You must ensure that you read, understand and comply with this policy.

2. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

3. You must notify the HR manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

4. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

5. If you believe or suspect a breach of this policy has occurred or that it may occur you must notify the HR manager as soon as possible.

6. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the HR manager as soon as possible.

7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the HR manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally with the HR manager.

This policy is supported by our code of conduct, procurement policy and whistleblowing policy. Together, these documents set expectations for ethical conduct across our operations and supply chains. Our policies are reviewed at least annually by the HR manager and approved by the board.

Our policies on modern slavery and human trafficking

1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

2. We at Proctor & Stevenson have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

3. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with the Modern Slavery Act 2015.

4. We expect the same high standards from all of our contractors, suppliers  
   and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children,  
   and we expect that our suppliers will hold their own suppliers to the same  
   high standards.

5. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

Due diligence in our operations and supply chains

We apply proportionate due diligence to assess and manage modern slavery risks in our operations and supply chains. Our current processes include:

• screening key suppliers against legal and ethical criteria before engagement

• including contractual obligations on modern slavery, human rights and compliance in supplier agreements

• requesting information from higher risk suppliers on their own policies, training and supply chain controls

• responding promptly to any concerns raised about a supplier, including suspension or termination where appropriate.

Modern slavery risk assessment and management

We recognise that our direct operations present a relatively lower risk of modern slavery, as our workforce is predominantly professional employees based in the United Kingdom. However, we may be indirectly exposed to higher risks in parts of our supply chain, for example:

• facilities and cleaning services

• print, promotional merchandise and physical production

• information technology hardware and some offshore services.

We assess risk by considering sector, geography, type of service and the structure of the workforce involved. Higher risk suppliers are subject to increased scrutiny, including enhanced due diligence and, where appropriate, additional contractual requirements and ongoing dialogue on working conditions.

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