Purpose and scope

This policy sets out how Border Crossing Media Holdings Limited, trading as Border Crossing UX, approaches corporate social responsibility, social value and sustainable procurement.

Border Crossing UX is a research and experience design consultancy. Its responsibilities arise through the way it conducts business, treats people, commissions and delivers work, purchases goods and services, and considers the effects of its decisions on clients, client customers, research participants, suppliers, communities and the environment.

The policy applies to Company Directors and employees and, where relevant to their engagement, associates, specialist suppliers and other people or organisations acting for or on behalf of the company.

Requirements are applied proportionately to the company’s size, services, influence and the potential impact or risk of the activity.

Our principles and values

Corporate responsibility is integrated into the company’s strategy, operations and delivery. Our current values guide how this policy is applied:

Collaborative. We build consensus and momentum through respect, empathy and constructive feedback.

Driven. We embrace complexity and work through challenges to deliver results that matter.

Considered. We respect context and assess the potential effects of our actions on people, communities and the environment.

Pragmatic. We focus on solving the right problem so that effort and resources are used well.

These values are supported by the following principles:

Integrity. Decisions, claims, records and communications must be honest, evidence-based and appropriately transparent.

Fairness. People should be treated with dignity and respect, without unlawful discrimination, harassment, victimisation or unnecessary exclusion.

Responsibility. The company considers the interests of people and communities affected by its activities and raises material risks or trade-offs.

Proportionality. Controls and expectations reflect the scale, risk and impact of the activity and avoid unnecessary burdens on small or specialist suppliers.

Whole-life value. Purchasing decisions consider quality, accessibility, security, environmental impact, maintainability and total cost, not only initial price.

Improvement. Where a responsible improvement can be agreed and monitored, the company may work with a supplier or partner rather than automatically exclude them.

Evidence. Environmental, social-value, diversity and ethical claims must be capable of being supported by reasonable evidence.

Responsibility

Company Directors

The Company Directors are responsible for approving and overseeing this policy. They are responsible for:

  • setting the company’s corporate responsibility and sustainable procurement expectations
  • ensuring material social, ethical and environmental risks are considered
  • approving material supplier commitments and exceptions
  • reviewing performance and improvement priorities
  • ensuring appropriate action is taken where concerns arise
  • ensuring procurement, social-value and public claims remain accurate.

Managing Director

The Managing Director coordinates the day-to-day operation of relevant supplier and associate due diligence, procurement decisions, environmental and social-value reporting, employment and people arrangements, community activity and supporting evidence.

Everyone acting for or on behalf of the company

  • act professionally, ethically and lawfully
  • treat people with respect
  • declare conflicts of interest
  • protect confidential and personal information
  • comply with applicable company and client requirements
  • avoid misleading environmental or social claims
  • report suspected breaches or harmful practices promptly.

A concern involving one Director must be reported to the other Director and considered without the involvement of the Director concerned.

Ethical business conduct

The company is committed to honest and fair business practices, accurate bids and records, fair competition, responsible marketing, protection of confidential and personal information, and compliance with contractual and professional obligations.

The company does not tolerate bribery, corruption, fraud, deliberate dishonesty, forced labour, human trafficking, deliberate facilitation of tax evasion, unlawful discrimination or material misrepresentation.

Detailed controls are maintained in the relevant policies and procedures. This policy does not duplicate those requirements.

People, fair work and labour standards

The company seeks to provide fair, lawful, inclusive and supportive working arrangements. It prohibits forced, bonded and compulsory labour, child labour, human trafficking and exploitative recruitment practices within its operations.

For employees and workers, as applicable, this includes:

  • providing clear written information about their employment conditions before employment begins
  • paying at least the applicable National Minimum Wage or National Living Wage
  • providing statutory benefits, leave, pension and other employment entitlements
  • maintaining working hours that comply with applicable law, are reasonable for the company’s sector and do not breach relevant International Labour Organization standards
  • not requiring forced or compulsory overtime
  • providing appropriate daily and weekly rest
  • ensuring employees receive at least one full day free from work in each seven-day period
  • not requiring an employee to work more than 7 consecutive days
  • providing safe and accessible working arrangements
  • providing reasonable adjustments
  • supporting appropriate workload management
  • respecting lawful freedom of association, trade-union membership and collective bargaining
  • allowing employees to terminate their employment in accordance with their contract and legal rights
  • providing regular feedback and performance discussions
  • completing annual performance and development appraisals
  • maintaining annual training plans
  • using personal development plans where additional development or support is required
  • providing fair grievance, disciplinary and capability procedures
  • protecting people from retaliation for raising genuine concerns.

Where the company uses temporary or agency workers, it will confirm that the provider applies lawful wage, working-time, rest, recruitment and employment arrangements.

The company does not charge candidates, employees or workers recruitment fees or require them to pay a financial deposit as a condition of securing or retaining work.

The company does not retain original passports, identity cards, immigration documents or other personal documents. Where an original document must be inspected for a lawful check, it is returned promptly. Copies are retained only where lawful, necessary and appropriately protected.

The company values employee views and seeks to provide the systems, information, tools and support needed to perform roles effectively. Flexible and remote working may be supported where appropriate to the role and business need.

Employee working conditions are monitored proportionately through management discussions, working-time and leave arrangements, health and safety processes, appraisals, grievances, absence information and exit feedback.

Equality, inclusion and accessibility

The company is committed to fair treatment, equality of opportunity, inclusion and accessibility. It seeks to prevent unlawful discrimination, harassment and victimisation, provide reasonable adjustments, use inclusive recruitment and working practices, and avoid unnecessary barriers to participation or supply.

Accessibility and inclusion are considered alongside quality, cost and delivery requirements rather than being treated as optional additions. Supplier and procurement requirements should not create unjustified barriers for disabled-led, minority-led, small or specialist businesses.

Health, safety and wellbeing

The company seeks to protect the health, safety and wellbeing of employees, associates, research participants and others affected by its activities. Relevant arrangements include workplace and remote-working risk management, display-screen equipment assessment, fire and emergency arrangements, safe travel and fieldwork planning, participant support, workload and wellbeing discussions, reasonable adjustments, and reporting and investigation of incidents.

Associates and suppliers

Associates are independent businesses engaged under business-to-business agreements to deliver defined outcomes. Associate engagements are non-exclusive, outcome-led, time-limited or project-specific, and governed by clear contractual, confidentiality, security, quality and insurance requirements.

The company works with suppliers and associates respectfully and seeks relationships based on clarity, trust, fair dealing and shared responsibility. Expectations are proportionate to the value, duration, impact and risk of the relationship.

The company applies proportionate due diligence and considers ethical, environmental, accessibility, security, quality and social factors where they are relevant. It does not claim that every supplier is the most ethical, diverse or environmentally preferable option available.

The company aims to pay employees, associates and suppliers in accordance with agreed terms and to resolve genuine invoice questions promptly.

Clients, client customers and research participants

The company works with clients and their client customers in an open, transparent and respectful way. It seeks to add value through every engagement while being honest about evidence, uncertainty, risk and the limits of what the work can support.

When researching, advising on or designing products, services and experiences, the company considers reasonably foreseeable effects on:

  • clients and their employees
  • client customers, service users, members and citizens
  • research participants
  • disabled people and people with access needs
  • communities and groups who may be excluded or disadvantaged
  • the environment and wider society.

The company raises material risks, makes limitations and trade-offs clear, and avoids knowingly supporting unlawful, deceptive or seriously harmful activity. It does not claim that every recommendation will produce only positive effects.

Research participants are treated with dignity and respect. Research should be ethical, proportionate, accessible, inclusive, based on informed participation and designed to avoid unnecessary harm or burden. Detailed requirements are maintained in the Research Hub and related procedures.

Human rights and modern slavery

The company respects internationally recognised human rights and does not tolerate forced labour, compulsory labour, human trafficking, child labour, abusive or degrading treatment, or unlawful restrictions on worker freedom.

Its direct modern-slavery risk is low because it provides professional consultancy services and has a short, relatively transparent supply chain. Risk may nevertheless arise through electronics and IT equipment, facilities services, travel and accommodation, promotional goods, outsourced services or complex international supply chains.

The company carries out proportionate due diligence and escalates credible concerns. Where a material concern cannot be resolved, it may seek further evidence, require corrective action, obtain specialist advice, suspend purchasing, end the relationship or report the matter where appropriate.

The company’s minimum labour standards, annual risk-assessment process, reporting arrangements and detailed approach to preventing modern slavery, human trafficking, forced labour and child labour are set out in the Labour Standards and Modern Slavery Policy and our published Modern Slavery Statement.

Communities and social value

The company seeks to contribute positively to the communities and professional networks of which it is part. Social value may be created through:

  • supporting accessible and inclusive products and services
  • transferring knowledge and capability to client teams
  • engaging local associates and suppliers where appropriate
  • supporting professional development
  • sharing responsible research and design guidance
  • contributing to professional, education and community initiatives
  • charitable giving, sponsorship or pro bono work
  • speaking or contributing without charge for third-sector and education organisations where appropriate
  • reducing environmental impact and supporting fair working practices.

Employees may suggest organisations or initiatives for support. Organisations supported through charitable giving, sponsorship, professional contribution or pro bono work have included Family Journeys, The Turing Trust, Circus Starr, Maggie’s Edinburgh, The Tinderbox Orchestra, Byte Night, Safety Guides UK, and Strathclyde University Chamber Choir.

Social-value commitments must be relevant, deliverable, proportionate and capable of being evidenced. The company will not make inflated promises solely to improve a bid score.

Environmental responsibility

Environmental responsibilities are set out fully in the Environmental Policy and Carbon Reduction Plan. They include greenhouse-gas measurement and reduction, energy efficiency, pollution prevention, waste prevention and recycling, biodiversity and ecosystem considerations, water and marine resources, travel, physical and transition climate risk, supply-chain climate impacts and climate-related opportunities.

Environmental considerations form part of sustainable procurement where they are relevant and proportionate.

Sustainable procurement policy

The company uses a proportionate sustainable procurement process for purchasing goods and services. It considers the business need, whole-life value, environmental and social effects, accessibility, information security, quality, resilience, supplier capability, contractual requirements and total cost.

Sustainable procurement does not mean selecting the lowest-carbon or lowest-cost option without regard to whether it is secure, accessible, suitable, resilient or capable of meeting the need.

Before purchasing

Before making a material purchase or entering a significant supplier relationship, the company considers:

  • whether an existing asset, licence or service can meet the need
  • whether the requirement can be reduced
  • whether reuse, repair, sharing or refurbishment is suitable
  • whether the specification is proportionate
  • expected service life, maintenance and support
  • energy and resource use
  • end-of-life arrangements
  • supplier risk and dependency
  • whole-life cost and value.

For low-value routine purchases, this consideration may be brief and need not create a separate procurement document. For higher-value, higher-impact or strategically important purchases, relevant evidence and the decision are recorded through the ordinary approval, contract, proposal, supplier or Board process.

Environmental and climate considerations

Where relevant, the company considers energy efficiency, greenhouse-gas emissions, renewable-energy information, product life and durability, repairability, refurbished options, packaging, waste, recycling and end-of-life routes, travel and delivery requirements, pollution, biodiversity, water, supplier environmental policies, emissions reporting, Carbon Reduction Plans, climate targets and credible assurance.

Environmental information is considered critically. A supplier is not treated as environmentally preferable solely because it uses terms such as green, sustainable or carbon neutral, has announced a future Net Zero target, purchases offsets or publishes unsupported marketing material.

Material supply-chain climate impacts and dependencies are considered through the annual environmental and climate review. Relevant supplier categories include premises, energy, cloud and software services, IT equipment, travel and accommodation, associates, and professional or specialist suppliers.

Social, ethical and operational considerations

Where relevant, the company considers lawful and fair employment practices, modern-slavery and human-rights risk, equality and inclusion, accessibility, health and safety, ethical business conduct, fraud and corruption risk, tax compliance, conflicts of interest, responsible use of data and AI, community contribution, information security, data protection and service continuity.

Supplier due diligence and expectations

Supplier due diligence is proportionate to value, duration, business criticality, environmental and social impact, access to money, systems, information or client assets, geographic and supply-chain complexity, and client or contractual requirements.

Due diligence may include:

  • confirming the supplier’s identity or legal status and authority to contract
  • reviewing capability and experience
  • checking insurance
  • considering security and data protection
  • reviewing relevant policies, certifications or public evidence
  • reviewing environmental or emissions information
  • considering modern-slavery and ethical risks
  • checking payment and invoicing details
  • declaring and managing conflicts of interest.

Minimum supplier labour standards

Suppliers and associates are expected to:

  • comply with applicable employment, wage, working-time, health and safety and human-rights law
  • prohibit slavery, servitude, forced, bonded and compulsory labour
  • prohibit human trafficking and child labour
  • not charge workers exploitative or unlawful recruitment fees
  • not require workers to provide financial deposits as a condition of work
  • not confiscate or retain workers’ original passports, identity cards or personal documents
  • provide workers with clear information about their employment conditions
  • provide lawful wages, statutory benefits, working hours and rest
  • respect lawful freedom of association, trade-union membership and collective bargaining
  • maintain safe and respectful working conditions
  • enable concerns to be raised without retaliation
  • cooperate with proportionate checks, investigation and corrective action.

Supplier monitoring is proportionate to the value, duration, location, labour model, supply-chain complexity and assessed risk of the relationship.

Depending on the risk, checks may include:

  • reviewing a supplier’s labour, human-rights or modern-slavery policy
  • reviewing a published modern-slavery statement
  • confirming whether labour providers or subcontractors are used
  • asking about recruitment practices, worker-paid fees and identity-document controls
  • requesting relevant evidence or assurances
  • reviewing credible public information
  • recording concerns and agreed corrective action.

The company does not conduct routine physical audits of every supplier. A site audit, worker interview or specialist assessment may be considered where the assessed risk or available evidence justifies it.

The company may request evidence of relevant awareness or training from a higher-risk or strategically important supplier. It does not require every supplier to provide modern-slavery training.

The company does not require every supplier to publish a formal policy, certification or Carbon Reduction Plan. It considers the supplier’s scale, the nature and risk of the requirement, other available evidence, whether proportionate improvement can be agreed and whether the remaining risk is acceptable.

A Carbon Reduction Plan or equivalent information may be requested where the purchase is high value, the supplier is environmentally significant or operationally critical, the service contributes materially to company emissions, a client or contract requires it, or the information is needed to improve Scope 3 reporting.

Operational sourcing, supplier criticality, supply-chain risk assessment, performance monitoring, incident management, business continuity and exit arrangements are governed by the company’s Sourcing, Supplier and Supply Chain Risk Management Policy and Procedures.

Associates and specialist suppliers

Associates and specialist suppliers are expected to comply with applicable law and agreed contractual requirements. Where relevant to the engagement, they are encouraged or required to minimise unnecessary business travel, use appropriate lower-emission travel, use energy-efficient equipment, maintain equipment for as long as it remains safe and suitable, use appropriate repair and recycling routes, follow project-specific environmental requirements and provide relevant emissions or travel information where contractually required.

The company does not control associates’ wider businesses. Requirements are limited to matters that are proportionate and relevant to the engagement.

Decisions, approval and conflicts

A procurement decision balances fitness for purpose, quality, accessibility, security, environmental and social impact, supplier risk, resilience, whole-life cost, affordability and client requirements.

Environmental or social factors may justify selecting an option that is not the cheapest where it provides better overall value and remains proportionate. Material commitments, exceptions or unusual supplier arrangements require approval under the company’s delegated authority and financial controls.

Potential conflicts of interest must be declared and managed before a purchasing decision is made.

Supplier engagement and improvement

Where appropriate, the company may work with a supplier to improve environmental reporting, emissions data, equipment and waste arrangements, accessibility, information security, working practices, contractual clarity, continuity or social-value outcomes.

Improvement actions should be relevant, proportionate, time-bound where necessary, capable of being evidenced and reviewed according to the level of risk.

The company may suspend or terminate a relationship where serious harm is identified, legal or contractual requirements are not met, information is deliberately misrepresented, a material risk remains unresolved or agreed corrective action is not completed.

Procurement and supplier records

The company retains proportionate records of material purchasing decisions, approvals, supplier and associate due diligence, contracts and Statements of Work, relevant environmental or social evidence, conflicts of interest, improvement actions, supplier concerns and client-specific requirements.

Records may be held within supplier folders, contracts, proposal and approval records, financial systems, Board papers and minutes, the existing company action tracker or project records. A separate sustainable-procurement register is not required for the company’s current scale and purchasing profile.

Reporting concerns

Anyone who identifies a suspected breach of this policy should report it promptly to either Company Director. The receiving Director will assess the nature and seriousness of the concern, whether immediate action is needed, who or what may be affected, whether a supplier or activity should be paused, whether specialist advice or investigation is required, and what corrective action should follow.

A concern involving one Director must be reported to the other Director and considered without the involvement of the Director concerned. No person will suffer retaliation or disadvantage for raising a genuine concern.

Client assurance

The company is willing to provide clients with appropriate policies, procedures, supplier due-diligence information, environmental information, social-value evidence and redacted procurement or review records. Disclosure remains subject to confidentiality, security, data-protection and commercial considerations.

Monitoring and review

The Company Directors review the operation of this policy at least annually. The review considers material procurement decisions, supplier and associate risks, environmental and climate findings, employment and fair-work matters, accessibility and inclusion, labour standards, modern-slavery and human-rights risks, relevant supplier checks and resulting corrective actions, social-value commitments, incidents and concerns, progress against actions, and changes to legal, contractual, client or insurance requirements.

The review uses existing business records and is documented through the relevant Board paper, Board minutes and existing action tracker. The policy is also reviewed following a material supplier concern, significant procurement decision, environmental or social incident, material change to company operations, significant legal or client requirement, or identified weakness.

Last reviewed and approved

20 July 2026