Modern Slavery and Human Trafficking Policy
Document Index
Introduction and Commitment
Policy Statement
Definitions
Scope
Responsibilities
5.1 Board of Directors
5.2 Senior Management
5.3 All EmployeesDue Diligence Processes
Risk Assessment
Training
Reporting and Whistleblowing
Monitoring and Review
Breach Management
1. Introduction and Commitment
As a responsible global business, IID Media Limited recognises our duty to prevent modern slavery throughout our operations and supply chains. This policy reflects our zero-tolerance approach and commitment to ethical business practices, ensuring compliance with the UK Modern Slavery Act 2015 and international human rights standards.
2. Policy Statement
IID Media Limited has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically and with integrity in all our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
3. Definitions
Modern Slavery: Encompasses slavery, servitude, forced or compulsory labour, and human trafficking
Human Trafficking: The recruitment, transportation, transfer, harbouring or receipt of persons through force, fraud or deception
Forced Labour: All work or service which is exacted from any person under the menace of any penalty and for which the person has not offered themselves voluntarily
4. Scope
This 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, interns, agents, contractors, external consultants, third-party representatives and business partners.
5. Responsibilities
5.1 Board of Directors:
Overall responsibility for ensuring compliance
Annual review and approval of the Modern Slavery Statement
Allocation of resources for implementation
5.2 Senior Management:
Implementing and monitoring due diligence procedures
Ensuring staff awareness and training
Investigating concerns raised
5.3 All Employees:
Complying with this policy
Reporting concerns through appropriate channels
Completing required training
6. Due Diligence Processes
We conduct due diligence on both new and existing suppliers which includes:
Supplier pre-qualification assessments
Contractual provisions requiring compliance
Regular risk-based audits
Monitoring of high-risk jurisdictions and sectors
7. Risk Assessment
We maintain a risk register identifying:
Geographical areas with higher risk of modern slavery
Industry sectors with recognised risks
Specific supplier relationships requiring enhanced due diligence
Internal operational risks
8. Training
All relevant employees receive training on:
Identifying signs of modern slavery
Understanding reporting obligations
Implementing due diligence procedures
Understanding the Modern Slavery Act 2015 requirements
9. Reporting and Whistleblowing
Employees and third parties can report concerns:
Confidential Hotline: [INSERT NUMBER]
Email: [email protected]
Post: Modern Slavery Officer, IID Media Limited, Docklands Business Centre, 10-16 Tiller Road, London E14 8PX
We protect whistleblowers from detrimental treatment.
10. Monitoring and Review
We monitor effectiveness through:
Annual supplier audits
Incident tracking and resolution
Employee feedback and training evaluation
Benchmarking against industry best practice
11. Breach Management
Any breach of this policy may result in:
Disciplinary action against employees
Termination of supplier relationships
Reporting to appropriate authorities
Legal action where appropriate
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.
Policy Owner: Chief Executive Officer
Review Frequency: Annual
Next Review Date: 28th November 2026
Approved by: Board of Directors, IID Media Limited
Date: 28th November 2025