Anti-Slavery Policy

SLAVERY & HUMAN TRAFFICKING POLICY

INTRODUCTION

AKA is committed to improving our practices to combat slavery and human trafficking. We have a zero-tolerance approach to modern slavery and we strive to act ethically and with integrity in all of our business dealings and relationships to ensure that modern slavery is not taking place anywhere in our own business or in any of our supply chains. We shall also ensure our approach and stance is clear with our partner organisations.

ORGANISATIONAL STRUCTURE

1.AKA Ltd (The Company) is controlled by a Board of Directors. The Company’s Head Office is located in London, with another UK office located in Manchester. The Company is part of The AKA Group Ltd.2.The Company is predominately involved in the provision of Marketing, Advertising, Media & Design services to the Theatre, Arts, Culture & Heritage sectors in both telephone, email and face to face consultancy formats, for which demand is consistent throughout the year.

DEFINITIONS

The Company considers that modern slavery encompasses:

  1. Human trafficking;
  2. Forced work, through mental or physical threat;
  3. Being owned or controlled by an employer through mental or physical abuse or thethreat of abuse;
  4. Being dehumanised, treated as a commodity or being bought or sold as property;
  5. Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT

  1. The Company acknowledges its responsibilities under the Modern Slavery Act 2015 and is committed to preventing slavery and human trafficking within its own businesses and in its supply chains. The Company understands that this requires an ongoing review of both its internal practices in relation to its labour force and its supply chains.
  2. The Company has a zero tolerance policy towards modern slavery. It will refrain from entering into business, and/or will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.
  3. The labour supplied to The Company in pursuance of the services it provides is carried out wholly in the countries where those services are provided i.e. United Kingdom, United States.
  4. No labour provided to The Company in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.
  5. Part-time and fixed-term employees within The Company are provided with the same pro-rata contractual entitlements as full-time and permanent employees. If these are not offered, The Company is able to rely on objectively justifiable grounds.
  6. Company employees are offered a competitive remuneration package and TheCompany prides itself on the additional benefits it is able to offer its employees on a wide variety of platforms. It conducts staff surveys on an anonymous basis to give employees a voice on their individual employment, their department and The Company as appropriate. Commitment to creating career progression in a supportive environment is a key facet of our HR strategy.

POTENTIAL EXPOSURE

  1. The Company considers its exposure to modern slavery to be limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.
  2. In the operation of its business, The Company’s main supply chains are those related to the provision of services. The Company considers its main exposure to the risk of slavery and human trafficking to exist in its supply chains.

STEP

  1. The Company carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its supply chains. To be reviewed in 2022.
  2. The Company has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with slavery and/or human trafficking.
  3. In accordance with section 54(4) of the Modern Slavery Act 2015, The Company has contacted (or attempted to contact) all first tier suppliers to set out our zero tolerance stance on modern slavery and to ensure that slavery and/or human trafficking is not taking place.
  4. The Company has taken action to monitor reports of modern slavery and will cross reference such reports with our first tier supply chain. The Company will seek to discontinue business with any first tier supplier found by the enforcement authorities to be involved in modern slavery.
  5. The Company encourages use of its whistleblowing policy to report any concerns regarding modern slavery and will investigate any complaints thoroughly.

TRAINING

  1. Upon commencement of employment, all employees undergo a structured induction process. All employees are made aware of The Company policies relating to standards of behaviour that it requires from them.
  2. The Company also highlights an awareness of modern slavery to all staff, by publishing details on the intranet. The Company ensures that annual updates are published.

ASSESSMENT OF EFFECTIVENESS IN COMBATTING MODERN SLAVERY

  1. To ensure effectiveness in combatting modern slavery, The Company maintains an accurate supplier list including contact details. It will ensure action is taken in response to reports of modern slavery in its supply chains and any complaints made via the whistleblowing policy will be responded to in accordance with the policy.
  2. Following a review undertaken in 2019, The Company confirms its supplier list is up to date for the current financial year.
  3. As in the previous financial year, there have been no reports that any of The Company’s suppliers have been involved in activities covered by the Modern Slavery Act.

POLICIES

The Company also has a Corporate Social Responsibility Policy which further defines its stance on modern slavery. In addition, a Whistleblowing policy is in place which encourages the reporting of any wrongdoing which is in the public interest.

DATA PROTECTION & COMPLIANCE

The Company has a Director who is responsible for Data Protection & Compliance, to whom all concerns regarding modern slavery should be addressed. This Director undertakes an annual review of The Company’s obligations towards eradicating modern slavery within its organisation and supply chains.

REVIEW

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2010 and applies to AKA Promotions Ltd. It is reviewed for each financial year.

Updated : May 2021 By Adrian Allen

Next Update : May 2022