Introduction

Border Crossing Media Holdings Limited, trading as Border Crossing UX, is committed to preventing modern slavery and human trafficking in our business and supply chain.

We are not legally required to publish a modern slavery statement under section 54 of the Modern Slavery Act 2015, as we do not meet the statutory turnover threshold for relevant commercial organisations. However, we have chosen to publish this statement voluntarily to set out our ethical commitments, responsibilities and proportionate approach to managing modern slavery risks.

We have a zero-tolerance approach to slavery, servitude, forced, bonded or compulsory labour, human trafficking, child labour and other forms of labour exploitation. We expect everyone working for us, or on our behalf, to act ethically, responsibly and in accordance with applicable law.

This statement sets out the steps we take to identify, assess and manage modern slavery risks in a way that is proportionate to the size, nature and risk profile of our business.

Our detailed operational requirements are set out in our internal Labour Standards and Modern Slavery Policy.

Organisation, business and supply chain

Border Crossing UX is a UK-based professional services company providing research, strategy, experience design, content and related consultancy services.

Our services are primarily office-based, remote and digital. Delivery is usually carried out by our Directors, employees and approved associates using standard business systems and professional tools.

Our supply chain is limited and mainly consists of:

  • cloud software and digital tools, including collaboration, design, research, productivity and file storage platforms
  • professional services, such as accountancy, legal, insurance and business support
  • IT equipment and office supplies, such as laptops, peripherals, stationery and furniture
  • office and facilities-related services, where relevant
  • travel and accommodation services
  • associates and specialist suppliers engaged through business-to-business arrangements
  • occasional promotional, printed or workshop materials.

We assess the risk of modern slavery in our direct operations as low. However, we recognise that modern slavery risks can exist in indirect supply chains, particularly where goods or services involve manufacturing, logistics, facilities, recruitment, agency labour or lower-paid labour-based work.

Our policy and commitments

We are committed to:

  • acting ethically and with integrity in all business relationships
  • maintaining fair, lawful and freely chosen working arrangements
  • prohibiting slavery, servitude, forced, bonded and compulsory labour, human trafficking and child labour
  • not charging candidates or workers recruitment fees or requiring financial deposits
  • not retaining original passports, identity documents or other personal documents
  • not knowingly supporting or doing business with organisations involved in modern slavery or human trafficking
  • requiring Directors, employees, associates and relevant suppliers to report concerns
  • protecting people who raise genuine concerns from retaliation or victimisation
  • considering the interests and safety of anyone who may be affected by exploitation
  • reviewing our approach annually and improving it where necessary.

This statement applies to Company Directors and employees, workers, approved associates, specialist suppliers and other people or organisations acting for or on behalf of the company.

The Company Directors are responsible for approving and overseeing our approach. The Managing Director coordinates the annual assessment, relevant supplier checks, training records and supporting evidence.

Supplier expectations and due diligence

We expect suppliers and associates to comply with applicable employment, wage, working-time, health and safety and human-rights law.

They must not use slavery, forced or bonded labour, human trafficking or child labour. They must not charge workers exploitative or unlawful recruitment fees, require financial deposits, or confiscate or retain workers’ original identity documents.

We take a proportionate, risk-based approach to supplier due diligence.

Before appointing or renewing relevant suppliers, we may consider:

  • the nature of the goods or services being provided
  • the country or region in which the supplier operates
  • whether labour-intensive, outsourced or agency-based delivery models are used
  • whether subcontractors, labour providers or recruitment intermediaries are involved
  • whether the supplier has relevant modern slavery, ethical trading or responsible sourcing arrangements
  • whether the supplier is subject to recognised legal, regulatory or professional requirements
  • whether any concerns, adverse information or warning signs have been identified
  • whether low-paid, temporary, migrant, seasonal or otherwise vulnerable workers may be involved.

For higher-risk suppliers or purchasing categories, we may request additional information, review published policies or statements, seek written assurances, include contractual expectations, agree improvement actions or decide not to proceed.

We do not require every supplier to maintain a formal modern slavery policy, provide annual training or undergo a physical audit. The level of due diligence and monitoring reflects the nature and assessed risk of the relationship.

Where concerns are identified, they are reviewed by a Director and appropriate action is taken. This may include further checks, remediation, escalation, suspension of work or termination of the relationship.

Risk assessment and management

The risk of modern slavery in our own operations is considered low because our work is professional, knowledge-based and delivered by a small UK-based team.

The areas where risk could be higher are mainly indirect supply-chain categories, including:

  • IT hardware and electronics, due to global manufacturing and raw-material supply chains
  • furniture and office supplies, due to manufacturing, logistics and labour practices
  • facilities and cleaning services, where relevant
  • recruitment, agency labour and other third-party labour arrangements
  • third-party services delivered through complex or international supply chains
  • travel and accommodation
  • promotional products and printed materials
  • services involving low-paid, temporary, migrant, seasonal or otherwise vulnerable workers.

We manage these risks by:

  • using reputable suppliers 
  • reviewing higher-risk purchases before appointment or renewal
  • setting clear expectations around ethical conduct and legal compliance
  • ensuring associates and specialist suppliers are engaged on clear terms
  • avoiding suppliers where there are credible concerns about labour exploitation
  • carrying out proportionate supplier checks
  • recording material concerns, decisions and actions
  • escalating and reviewing concerns promptly.

The Company Directors complete a documented labour standards and modern slavery risk assessment at least annually. It is also reviewed when there is a material change to our workforce, recruitment arrangements, supply chain, legal obligations or risk profile.

Effectiveness and monitoring

We monitor the effectiveness of our approach using proportionate indicators. These include:

  • Policy review: this statement and the supporting internal policy are reviewed at least annually.
  • Risk assessment: a documented annual assessment is completed.
  • Supplier due diligence: relevant suppliers and higher-risk purchasing categories receive proportionate checks.
  • Issue reporting: concerns are recorded, reviewed and escalated.
  • Supplier action: appropriate action is taken and documented where concerns are identified.
  • Employment controls: material concerns relating to pay, working hours, recruitment practices or identity documents are investigated.
  • Awareness: relevant people receive appropriate induction and refresher information.
  • Improvement actions: agreed actions are assigned, tracked and reviewed.

We do not operate a large or complex supply chain. Our approach is therefore focused on practical risk awareness, proportionate due diligence and prompt escalation of concerns.

Training and awareness

Company Directors and employees are expected to understand our zero-tolerance approach to modern slavery and human trafficking and the labour standards that support it.

Relevant requirements are communicated proportionately to associates, workers and specialist suppliers where their role or engagement creates exposure to the identified risks.

Awareness is provided through:

  • access to this statement and the supporting internal policy
  • induction or onboarding information
  • periodic refresher training, briefings or updates
  • project-specific guidance where relevant
  • clear routes for raising concerns.

Training and awareness may cover forms of modern slavery, potential warning signs, recruitment fees, worker debt, document retention, restrictions on workers’ freedom and how concerns should be reported.

Reporting concerns

We encourage anyone connected with our business to raise concerns about suspected modern slavery, human trafficking, forced labour or exploitation.

Concerns should be reported to either Company Director. They may also be sent to hello@bordercrossingux.com and marked for the attention of a Company Director.

A concern involving one Director should be reported to the other Director and considered without the involvement of the Director concerned. Where internal reporting would be inappropriate, concerns may be raised through an appropriate external reporting route.

Concerns will be reviewed promptly and appropriate action will be taken.

We will not tolerate victimisation or detrimental treatment of anyone who raises a genuine concern in good faith, supports another person’s report or participates in a review or investigation.

Response and remediation

Where a concern is identified, we will consider:

  • the seriousness of the concern
  • who may be affected or at risk
  • whether urgent protective action is required
  • whether an activity, purchase or engagement should be paused
  • whether specialist advice or external reporting is required
  • what corrective, remedial or preventative action is appropriate.

Action may include further investigation, supplier engagement, support for an affected person, additional monitoring, suspension or termination of a relationship, or reporting the matter to an appropriate authority.

We will consider the interests and safety of any affected worker. Immediate termination of a supplier relationship will not be treated as the only possible response where it could increase the risk of harm.

Review and approval

This statement is reviewed annually, or sooner if there are material changes to our business, workforce, supply chain, legal requirements or risk profile.

Last reviewed and approved

This statement was reviewed and approved by the board of directors of Border Crossing Media Holdings Limited on 20 July 2026