Modern Slavery and Human Trafficking Policy

1. POLICY STATEMENT

Modern slavery is a crime and a violation of fundamental human rights. It can take many forms, including forced labour, slavery, servitude and human trafficking. It involves the exploitation of someone for the benefit of someone else (including organisations).

We have a zero-tolerance approach to modern slavery, and we’re committed to ensuring we have effective systems and controls in place to ensure modern slavery is not taking place in our own business or supply chain.

This policy applies to all employees and anyone working on our behalf. It doesn’t form Part of your contract of employment so we may amend it any time.

2. RESPONSIBILITY

Our Board has overall responsibility for ensuring this policy complies with its legal and ethical obligations and that we all comply with it.

Day-to-day responsibility for implementing the policy sits with the Executive Director, along with monitoring the use and effectiveness of it, dealing with queries and auditing internal control systems and procedures.

It’s the responsibility of line managers to ensure that their teams understand and comply with this policy. The Finance and Sustainability Subcommittee receives reports from the Director of Finance, the Operations Director and all other relevant managers to ensure that this policy is implemented thoroughly throughout all applicable steps in the Procurement process.

3. COMPLIANCE

It is imperative that you read, understand, and comply with this policy, any breaches of policy may be dealt with via the disciplinary process.

To support our zero-tolerance approach to modern slavery, we have built specific contractual provisions relating to modern slavery into our procurement process.

The process has the following procedures with our contracting and supply chain:

• Before procurement takes place, we will use a series of key characteristics (such as sourcing geography, industry type, nature of work and supply chain model) to identify whether the contract is at high or medium risk of modern slavery occurring and, based on this we will make sure that any further procurement and contract management activity are proportionate.
• We may also require proposed suppliers to:
• Provide evidence of the recruitment methods used for staff delivering the contract.
• Provide details of workforce conditions in factories used to produce goods to be delivered under the contract, including wages, working hours and rest breaks; and
• Provide evidence of the processes which they have in place to identify and address modern slavery risks in their supply chains; and
• complete a specified Modern Slavery Assessment Tool (“MSAT”)
• In our supply contracts and standard terms of business we’ve included express terms requiring our counterparties to comply with all applicable laws relating to anti-slavery and human trafficking. In addition to requiring them to include similar terms in their own contracts and subcontracts. We must also be notified if they become aware of any slavery or human trafficking in their own supply chains.
• We require all current suppliers to confirm, in writing that:
• They, and their direct supply chain, do not endorse, enable or facilitate human trafficking or slavery within their business.
• We will undertake close contract management of higher risk agreements and may carry out internal and/or external audits, site-visits or spot-checks of all suppliers and their supply chain to verify compliance with applicable laws and may require existing suppliers to complete the MSAT.

We will investigate any supplier who fails to comply with our terms, which may result in us taking necessary actions to prioritise the safety and security of actual or potential victims of slavery; we may ultimately terminate the contract.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all of us. Annual modern slavery training is mandatory and designed to help create a deeper understanding of the effects and implications of modern slavery and to help us to avoid breaches of this policy.

If you believe a breach of policy has, or is likely to occur, you must notify the Executive Director and we encourage you to do this at the earliest opportunity. You will be asked to share relevant information, which will be treated with sensitivity, you must not share the information with any other person without the express permission of the Executive Director. As an alternative, you can also report any concerns via the Modern Slavery Helpline on 0800 121 700 or online at www.modernslaveryhelpline.org. who are an independent. Confidential body.

If you have a concern but are unsure whether it constitutes a breach, then please speak to the Executive Director who will work with you to determine any further action.

We encourage openness and will support you if you raise a concern, even if it turns out to be mistaken (as long as it is raised in good faith) and will not suffer any detrimental treatment as a result. 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 Executive Director immediately. If the matter is not resolved to your satisfaction, you have the option of raising a grievance (see the Grievance Policy).

4. BREACHES

We will prioritise the safety and security of victims of slavery and will work to implement remedial measures to improve their situation.

Breaches of this policy could result in disciplinary action, with penalties up to and including dismissal.

If you are not employed directly by us but are working on our behalf, we’ll review available actions to achieve the best outcome for victims. These may include suspension, the sharing of past performance information with other public sector contracting authorities and, where it doesn’t provide a perverse outcome for victims, termination of the relationship.

5. MONITORING

The Finance and Sustainability Subcommittee, the Executive Director and the Heads of Finance and Operations will monitor the implementation of this policy and any revisions, this will include:

• preparing an annual Modern Slavery Statement to be approved by the Board and shared with the public.
• overseeing implementation of the relevant training.
• monitoring our compliance with the relevant legislation.

6. REVIEW

This policy will be reviewed on an annual basis unless one of the following occur:

• We identify an error or omission.
• Our approach changes and we need to reflect this.
• Legislation changes and we need to amend it to reflect.

WHAT IS MODERN SLAVERY

Modern slavery is a crime and violation of fundamental human rights. Modern slavery can take many forms, including forced labour, slavery, servitude and human trafficking.

This crime can manifest itself in many ways, but what each of its forms will have in common is the exploitation of a person for another person or another person’s (or organisation’s) benefit.

The Modern Slavery Act 2015 (“MSA”) consolidates anti-slavery and human trafficking offences into one piece of legislation.

Under the MSA it is an offence to:

• (a) Hold another person in slavery or servitude or require another person to perform forced or compulsory labour.
• (b) Arrange or facilitate the travel of any person across borders with a view to that person being exploited (i.e. conduct or be involved in human trafficking); or
• (c) Commit an offence with the intention to commit human trafficking.

This statement is made pursuant to Section 54 (1) of the MSA and has been adopted by Bradford 2025 as our statement on modern slavery and human trafficking and was approved by the Board of Bradford Culture Company.

OUR SUPPLY CHAIN AND THE ASSESSMENT OF RISK

Given the nature of Bradford 2025’s business, the risk of modern slavery in our supply chain is considered low. However, we are not complacent about this risk and will take active steps to ensure that our suppliers, consultants and contractors, throughout our supply chain, are not engaging in any form of modern slavery and human trafficking.

We accept that no part of our business is immune to the risks of modern slavery and human trafficking, and we will not support or do business knowingly with a company involved in any form of modern slavery or human trafficking.

All persons working for Bradford 2025 must comply with our Anti-Slavery and Human Trafficking Policy. This policy sets out the steps we take to reduce the risk of modern slavery and human trafficking in all parts of Bradford 2025’s business and supply chains. We take compliance with this policy very seriously and any employee or Director who breaches this policy will face disciplinary action. Our Procurement Policy details the actions we take to combat modern slavery and human trafficking in our supply chain and to embed the mitigating controls in our daily operations.

Before commencing a procurement process, we use a series of key characteristics to identify the risk of modern slavery to the relevant contract so we can seek to ensure that the subsequent procurement and contract management activity is proportionate.

We may require proposed suppliers to provide us with evidence of compliance with anti-slavery and human trafficking laws, such as details of workforce conditions in their factories or evidence of the processes they have in place to identify modern slavery risks in their supply chains.

In our supply contracts and standard terms of business we have included express terms requiring our counterparties to comply with the MSA and our Anti-Slavery and Human Trafficking Policy, to implement procedures for its own personnel and suppliers to ensure there is no slavery or human trafficking in its supply chains, and to notify us if it becomes aware of any slavery or human trafficking in a relevant supply chain. We have also included provisions in our supply contracts which allow us to inspect and conduct an audit of a supplier’s and its sub-contractors’ premises to monitor compliance with the supplier’s obligations to comply with anti-slavery and human trafficking laws.

In addition, we require all current suppliers to make positive written affirmations that (i) they do not; and (ii) their direct supply chain does not endorse enable or facilitate human trafficking or slavery within their business, and we have built this requirement into our supplier process.

Failure by a supplier to comply with the processes described above will lead to an investigation and may result in the supplier’s contract being terminated.

Bradford 2025 has not highlighted and/or experienced any modern slavery issues within its supply chain to date.

OUR POLICIES & PROCESSES

Our policies reflect our commitment to pay employees fairly and properly for their work, act with integrity and ethically in our business relationships and use our best endeavours to enforce effective systems and controls across our supply chains.
Our employees are subject to, and benefit from, a wide range of policies including, anti-slavery and human trafficking, workplace behavior, disciplinary action, grievance and complaints, equal opportunities diversity and inclusion, and numerous other compliance policies. We also have a staff code of practice. All of our policies are subject to an equality impact assessment.

We operate a whistleblowing policy that enables anyone to raise any concerns and to have those concerns investigated. We also operate an exit interview process which provides staff with another forum to raise any concerns they may have about working practices.

We confirm the identities of all new employees and undertake employment checks to ensure they have a right to work in the United Kingdom.

As part of our ongoing commitment to understanding the risk of modern slavery and human trafficking, our Procurement staff will be receiving training in this area.

The policies and frameworks that we have in place limit the risk of modern slavery and human trafficking in the workplace and encourage all staff to work and act ethically.

CONTINUOUS IMPROVEMENT

As part of our ongoing commitment to eliminating modern slavery and human trafficking, we understand and recognise that our own circumstances and those of our suppliers are constantly evolving. We will continue to review our processes and assessments in relation to modern slavery and human trafficking to ensure they are fit for purposes, as part of our established risk framework; both as an employer and a purchaser of goods and services.

ANNUAL REVIEW

Bradford 2025 will conduct an annual review of this Statement and the actions it takes to combat all forms of modern slavery and human trafficking in its supply chain.