Anti-Slavery Policy
Organization
This statement applies to all companies within and associated to Macfarlane Media Limited (referred to in this statement as “The Group”). The information included in the statement refers to the financial year 2025.
Definitions
The Group considers that modern slavery encompasses: human trafficking
- forced work, through mental or physical threat
- being owned or controlled by an employer through mental or physical abuse or the threat of abuse
- being dehumanized, treated as a commodity or being bought or sold as property
- being physically constrained or having a restrictions placed on freedom of movement.
Commitment
The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labor force and, additionally, its supply chains. The Group does not enter into business with any other organization, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labor.
No labor provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the Unuted Kingdom, Unites States of America, Europe, Asia, and South Africa, [and in many cases exceeds those minimums in relation to its employees].
Organizational structure
In general, the Group considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organization that supplies services to it.
Due diligence in relation to modern slavery
The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organization or supply chains, including conducting a review of the controls of its suppliers.
Training
The Group provides training to staff to effectively implement its stance on modern slavery, and each member has access to the Group’s modern slavery policies. Monitoring and evaluation The Group constantly monitors and evaluates its effectiveness in ensuring modern slavery is not taking place in the Group or its supply chains.
Steps
The Group has not, to its knowledge, conducted any business with another organization which has been found to have involved itself with modern slavery. In accordance with section 54(4) of the Modern Slavery Act 2015, the Group has taken the following steps to ensure that modern slavery is not taking place:
- reviewing supplier contracts to incorporate termination rights in cases where the supplier is involved in, or suspected of being involved in, modern slavery
- Added clauses to all client contracts to include the Group’s non-tolerance for slavery and human trafficking, providing termination powers if the client is, or is suspected to be, involved in modern slavery
- measures in place to identify and evaluate the potential risks in its supply chains
- training provided to staff on modern slavery.
Modern slavery compliance officer
The Group has a modern slavery compliance officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Group’s obligations. This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.