Interstellar Television Limited – Modern Slavery Policy
What Is Slavery?
Modern slavery is a crime and a violation of fundamental human rights.
The UK’s Modern Slavery Act (MSA) 2015 covers four activities, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain:
|Where others exercise powers of ownership over a person (and so deprive the victim of their freedom)
|Where an individual is obliged to provide services by the use of coercion
|Forced or compulsory labour (including child labour)
|Where work or services are extracted from a person under the menace of any penalty (e.g. threats of violence, more subtle forms of compulsion) and for which the person has not offered him/herself voluntarily.Child labour is defined as children under 12 years working in any economic activity; those aged 12-14 engaged in more than light work; and all children engaged in the worst forms of child labour, which are defined here https://www.ilo.org/dyn/normlex/en/f?p=NORMLE XPUB:12100:0::NO::P12100_ILO_CODE:C182
|Where others arrange or facilitate the travel of another person with a view to that person being exploited. (This offence can be committed even where the victim consents to the travel as he/she may have been deceived by the promise of a better life or job etc.).
This policy applies to everyone working for us, or on our behalf in any capacity. It also applies to all goods and services we source.
How Is Modern Slavery Relevant to Us?
- Modern slavery is a complex and multi-faceted crime and the MSA 2015 recognises the important part businesses can play in tackling it. At first glance, individuals may think this subject is not relevant to our Company, but it is.
- At a very basic level, preventing exploitation and human trafficking, and protecting our workforce and reputation, by having high ethical standards, makes good business sense.
- With this in mind, we need to be sure that modern slavery and/or human trafficking is not taking place within our business operations or within our supply chain. We should consider that our supply chain may be at risk, although this is likely to be a low risk, in areas such as:
– Outsourced activities such as cleaning, waste management, etc.
– Short term hire of low skilled labour, here and abroad
– Sourcing of equipment and other materials if they are not from the UK, but from other locations in the world identified on the Slavery & Trafficking Risk Template (STRT) list here https://www.socialresponsibilityalliance.org/
Therefore the Company will:
- Have a zero-tolerance approach to any form of modern slavery and ensure there is transparency in our own business and in our approach to tackling modern slavery, to protect our workforce and our reputation
- Identify, understand and address the risks of forced/child labour and human trafficking in our own operations and supply chains, especially any outside of the UK
- Be clear about our recruitment policy
- Be clear with key suppliers what our expectations are regarding the Act
- Lead by example by making appropriate checks on all staff to ensure they have the right to work in the UK; make checks on any recruitment agencies and/or Contractors we use and our suppliers, to ensure we know who is working for us and to ensure that third parties supplying workers or services to our Company comply with our policy
- Make sure that all of our UK based suppliers pay their staff at least the national minimum/living wage; make sure that any international suppliers pay their staff any prevailing minimum wage applicable within their country of operations.
- Ensure we have in place an open and transparent grievance process for all staff to use
- Ensure that staff are aware of our whistleblowing policy and know that they can raise concerns about how colleagues are being treated or any bad practices within our business or supply chain, without fear of reprisal
- If we find that other individuals or organisations working on our behalf have breached this policy we will ensure we take appropriate action.
All Managers and staff have responsibilities to ensure workers are safeguarded, treated fairly and with dignity. Everyone must observe this Policy and be aware that ‘turning a blind eye’ to practices that may be modern slavery is unacceptable and not an option.
Identifying Victims of Slavery
There is no typical victim and some victims do not understand they have been exploited and are entitled to ask for help and support.
The crime can manifest in many different ways and sometimes it is not clear at what point, for example, poor working practices and a lack of health and safety awareness seep into instances of human trafficking, slavery or forced labour in a work environment. However businesses have a responsibility to ensure that workers are not being exploited, that they are safe and that the relevant employment, health and safety and human rights laws and international standards are adhered to.
However, the following could indicate that someone may be a slavery or trafficking victim:
- The person is not in possession of their own passport, identification or travel documents.
- The person is acting as though they are being instructed or coached by someone else.
- They allow others to speak for them when spoken to directly.
- They are dropped off and collected from work.
- The person is withdrawn or they appear frightened.
- The person does not seem to be able to contact friends or family freely.
- The person has limited social interaction or contact with people outside theirimmediate environment.
If you have any suspicions or concerns about modern slavery in any parts of our business or our supply chains, report it to your Manager immediately.
This policy has been approved by the Board of Directors and may be amended from time to time to ensure it complies with our legal and ethical obligations.