Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.
JBi Digital has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. JBi Digital also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, JBi Digital accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
This policy applies to all individuals working for JBi Digital or on JBi Digital’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
Responsibility for the policy
The board of directors has overall responsibility for ensuring that this policy complies with JBi Digital’s legal and ethical obligations.
The directors have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in JBi Digital’s business or supply chains.
Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.
Compliance
The prevention, detection and reporting of modern slavery in any part of JBi Digital’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for JBi Digital or under JBi Digital’s control.
JBi Digital aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. JBi Digital is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
If a breach or conflict with this policy is seen or suspected by an individual working for JBi Digital or on JBi Digital’s behalf, this should be reported to senior management immediately. The government’s Modern Slavery Helpline is also available on 0800 0121 700 for further information and guidance on modern slavery.
Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.
JBi Digital’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
Breach of this policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.
JBi Digital may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.