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Modern Slavery Policy


NineTwo Design Limited Modern Slavery Policy

Last updated [Feb] 2023

  • Definition of “slavery”
    • The Modern Slavery Act (MSA) 2015 covers four activities:
Slavery Exercising powers of ownership over a person
Servitude The obligation to provide services is imposed by the use of coercion
Forced or compulsory labour Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
Human trafficking Arranging or facilitating the travel of another person with a view to their exploitation
  • This policy covers all four activities.
  • How is it relevant to us?
    • Modern slavery is a complex and multi-faceted crime and tackling it requires all of us to play a part. At first glance, you may think this whole subject is irrelevant to us, but it’s not.
    • The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
    • With this in mind, we need to pay particularly close attention to:
      • our supply chain;
      • any outsourced activities, particularly to jurisdictions that may not have adequate safeguards;
      • our use of third party contractors in providing our services;
      • the working conditions of our own colleagues;
    • Responsibilities
      • NineTwo Design Limited is a company registered in Scotland with Company Registration Number SC727976 and having its registered office at First Floor, 11 Ashley Street, Charing Cross, Glasgow, Scotland, G3 6DR (“NineTwo”) and our managers and colleagues have responsibilities to ensure our fellow workers are safeguarded, treated fairly and with dignity.
      • Everyone must observe this policy and be aware that turning a blind eye is unacceptable and simply not an option.
      • Organisation responsibilities
        • We will:
          • maintain clear policies and procedures preventing exploitation and human trafficking, and protecting our workforce and reputation
          • be clear about our recruitment policy (see Recruitment)
          • check our supply chains (see Supply chains)
          • lead by example by making appropriate checks on all employees, recruitment agencies, suppliers, etc. to ensure we know who is working for us
          • ensure we have in place an open and transparent grievance process for all staff
          • seek to raise awareness so that our colleagues know what we are doing to promote their welfare
        • Manager responsibilities
          • Managers will:
            • listen and be approachable to colleagues
            • remain alert to indicators of slavery (see Identifying slavery)
            • raise the awareness of our colleagues, by discussing issues and providing training, so that everyone can spot the signs of trafficking and exploitation and know what to do
            • use their experience and professional judgement to gauge situations
          • Colleagues
            • We all have responsibilities under this policy. Whatever your role or level of seniority, you must:
              • keep your eyes and ears open—if you suspect someone (a colleague or someone in our supply chain) is being controlled or forced by someone else to work or provide services, follow our reporting procedure (see Reporting slavery)
              • follow our reporting procedure if a colleague tells you something you think might indicate they are or someone else is being exploited or ill-treated
              • tell us if you think there is more we can do to prevent people from being exploited
            • The risks
              • The principal areas of risk we face, related to slavery and human trafficking, include:
                • supply chains
                • general recruitment
                • use of third party contractors to provide our services
              • We manage these risk areas through our procedures set out in this policy and elsewhere.
            • Our procedures
              • Anti-slavery statement
                • Our company is a creative agency providing content production services on behalf of a number of medium to large client businesses. As an organization we provide content production services in the areas of graphic and web design and given the nature of our services we consider the risk of modern slavery within our supply chain to be low. However, we are committed to working ethically with our clients, subcontractors and employees and so consider modern slavery to be a fundamental issue not only in respect of its ongoing risk to businesses, but in the way it affects peoples’ lives on a daily basis.  We are therefore committed to ensuring that it does not take place anywhere in our business, including in our dedicated supply chains and our relationships with third party contractors.

NineTwo has a zero-tolerance policy towards modern slavery as a violation of fundamental human rights and as a crime.  This includes any and all forms of slavery, servitude and forced or compulsory labour. Our policy reflects our stance on the issue and highlights our commitment to remaining vigilant of modern slavery in our relationships, commitments and dealings, including within our own recruitment processes and our colleague engagement.

  • This policy sets out the key risk areas we face and our approach to avoiding and preventing modern slavery.
  • Supply chains
    • We thoroughly check supply chains to ensure the potential for slavery and human trafficking is significantly reduced.
    • We tell the companies we do business with that we are not prepared to accept any form of exploitation.
  • Recruitment
    • Recruitment
      • We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work.
      • We always ensure staff are legally able to work in the UK.
      • We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited).
      • We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to.
    • If, through our recruitment process, we suspect someone is being exploited, the recruitment team will follow our reporting procedures (See Reporting slavery).
  • Identifying slavery
    • There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
    • However, the following key signs could indicate that someone may be a slavery or trafficking victim:
      • the person is not in possession of their own passport, identification or travel documents;
      • the person is acting as though they are being instructed or coached by someone else;
      • they allow others to speak for them when spoken to directly;
      • they are dropped off at and collected from work;
      • the person is withdrawn or they appear frightened;
      • the person does not seem to be able to contact friends or family freely;
      • the person has limited social interaction or contact with people outside their immediate environment.
    • This list is not exhaustive.
    • Remember, a person may display a number of the trafficking indicators set out above but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right.
    • If you have a suspicion, report it.
  • Reporting slavery
    • Talking to someone about your concerns may stop someone else from being exploited or abused.
    • If you think that someone is in immediate danger, dial 999.
    • Otherwise, you should discuss your concerns with Jonathan Thomson who will decide a course of action and provide any further advice.
    • Not all victims may want to be helped and there may be instances where reporting a suspected trafficking case puts the potential victim at risk, so it is important that in the absence of an immediate danger, you discuss your concerns first with Jonathan Thomson before taking any further action.
  • Monitoring our procedures
    • We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.