This Modern Slavery statement and policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.
Border Crossing Media Holdings Ltd, trading as Border Crossing UX, strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Overall and final responsibility for ensuring this policy is adhered to is that of the Managing Director:
However, personal responsibility for the successful operation of this policy lies with every member of staff and contractor at Border Crossing Media Holdings Ltd.
Modern Slavery and Human Trafficking
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
- We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
- The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf.
- Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
- We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
- We take a risk-based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked-based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.
- Consistent with our risk-based approach we may require:
- Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
- Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code.
- As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
Key performance indicators
In order to measure our commitments outlined above, we have set forth a set of Key Performance Indicators (KPIs). These KPIs align with our key aims to:
- Ensure that all decision-makers and staff are aware of these policies and are vigilant/can identify any risks in our supply chain
- Certify all clients and suppliers have the same commitment to upholding ethical and legal labour standards
- Conduct due diligence for existing clients and suppliers through an annual internal audit of our supply chain and clients
- Review and update our Modern Slavery Statement once per year and measure our progress against the KPIs, while also setting new KPIs as needed.
The KPIs set for 2022 are as follows:
1. Conduct training for all incoming staff, consultants and freelancers
Ensure all staff, consultants and freelancers have a thorough understanding of not only our Modern Slavery Policy but also a training course on what slavery and human trafficking in supply chains are and how to be vigilant/ identify these in the suppliers selected.
Target: 100% of existing staff are trained and any new hires undertake the course within one month of joining.
2. Ensure all clients and suppliers have Modern Slavery Policies and mitigation plans in place
We will only contract with suppliers who have a commitment to high ethical business standards covering migrant workers, ethical trading, responsible sourcing or human rights.
Target: 100% of all clients and suppliers are compliant with Modern Slavery standards and have a written policy in place.
3. Conduct client and supplier due diligence
We will conduct an annual internal audit of all contracts to ensure their policies are up to date/being maintained, and that there have not been any violations in line with the company’s zero-tolerance approach.
Target: 1 annual audit of clients and suppliers is conducted and then reviewed by the Board of Directors.
4. The company’s Modern Slavery Statement is reviewed and signed by the Director once a year
We will make any necessary changes and measuring against KPIs to ensure full legal and ethical compliance. This would include an assessment of the company’s purchasing practices with a focus on any purchasing that may be high risk (such as the purchasing of hardware and furniture).
Target: 1 annual review and update of the company’s Modern Slavery Policy conducted, with the Board of Directors sign off.
This document was last updated on 28/07/2022.