This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Golley Slater Group has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Golley Slater has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Business

The Golley Slater Group is a network of UK offices, helping clients overcome marketing challenges of all shapes and sizes. From changing behaviour to growing brands or boosting sales, our team make a real difference to local, national, and international clients.

Scope

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

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.

Our Policies

We operate multiple internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

• Child Labour and Vulnerable Workers policy. This policy sets out the organisation’s stance on child labour and prohibits the use of child labour and forced or compulsory labour across the Group and explains how employees can identify any instances of this and where they can go for help.
• Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
• Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
• Ethical Trading policy. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

Our Suppliers

Golley Slater operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that particular organisation has never been convicted of offenses relating to modern slavery [and on-site audits which include a review of working conditions]. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.

In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:

• They have signed up to our Supplier Code of Conduct which requires suppliers to agree to adhere to our policies and standards.
• They have taken steps to eradicate modern slavery within their business
• They hold their own suppliers to account over modern slavery
• (For UK based suppliers) They pay their employees at least the national living wage
• (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations
• We may terminate the contract at any time should any instances of modern slavery become known

Training

We regularly conduct training for relevant employees so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain. Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided, as necessary.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors, and business partners at the outset of our business relationship with them and reinforced.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

The policy will be reviewed on a continual basis to ensure compliance with latest legislation. The person with overall responsibility for the implementation and regular review of this policy is the Human Resource Director.

David Longden

Group Chief Executive