Introduction

Border Crossing Media Holdings Ltd, 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 modern slavery, forced labour, servitude, human trafficking and 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.

Organisation structure, business and supply chains

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

Our services are primarily office-based, remote and digital in nature. Delivery is usually carried out by our internal team 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.
  • Occasional specialist or freelance support, where needed and approved.

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.

Policies in relation to slavery and human trafficking

We are committed to:

  • Acting ethically and with integrity in all business relationships.
  • Not knowingly supporting or doing business with organisations involved in modern slavery or human trafficking.
  • Requiring staff, contractors, consultants, freelancers and suppliers to report concerns.
  • Reviewing our approach periodically and improving it where necessary.

    This statement applies to all people working for us or on our behalf, including directors, employees, contractors, consultants, freelancers and suppliers.

    Overall responsibility for this statement sits with the Managing Director.

    Due diligence processes

    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 the supplier uses labour-intensive, outsourced or agency-based delivery models.
    • Whether the supplier has its own modern slavery, ethical trading or responsible sourcing policies.
    • Whether the supplier is subject to recognised legal, regulatory or professional requirements.
    • Whether any concerns, adverse information or red flags have been identified.

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

    Where concerns are identified, these will be reviewed by a Director and appropriate action will be 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 or cleaning services, where relevant.
    • Recruitment, agency labour or freelance support, where individuals may be engaged through third parties.
    • Third-party service providers, particularly where services are delivered across complex or international supply chains.

    We manage these risks by:

    • Using reputable suppliers where possible.
    • Reviewing higher-risk purchases before appointment or renewal.
    • Avoiding suppliers where there are credible concerns about labour exploitation.
    • Setting clear expectations around ethical conduct and legal compliance.
    • Ensuring any contractors or freelancers are engaged on clear terms.
    • Escalating and reviewing any concerns promptly.

      Effectiveness and performance indicators

      We monitor the effectiveness of our approach using proportionate performance indicators.

      These include:

      • Policy review: This statement is reviewed at least annually.
      • Risk review: Higher-risk supplier categories are considered before appointment or renewal.
      • Issue reporting: Any modern slavery concerns are recorded, reviewed and escalated.
      • Supplier action: Where concerns are identified, appropriate action is taken and documented.
      • Awareness: Staff, contractors and freelancers are expected to understand and follow this statement.

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

      Training and awareness

      All staff, contractors, consultants and freelancers working with us are expected to understand our zero-tolerance approach to modern slavery and human trafficking.

      Awareness is provided through:

      • Access to this statement.
      • Induction or onboarding information where relevant.
      • Periodic reminders or updates.
      • Project-specific guidance where supplier, contractor or participant-related risks may arise.
      • Clear escalation routes for raising concerns.

      Anyone working for us or on our behalf should report any concern relating to modern slavery or human trafficking to the Managing Director.

      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 the Managing Director.

      Concerns will be reviewed promptly and appropriate action will be taken. This may include further investigation, supplier engagement, remediation, escalation to the relevant authority, or ending a supplier relationship.

      We will not tolerate victimisation or detrimental treatment of anyone who raises a genuine concern in good faith.

      Review and approval

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

      This statement has been approved by the Managing Director of Border Crossing Media Holdings Ltd, trading as Border Crossing UX.

      This document was last updated on 16/02/2026.