Conditions of use
Modern Slavery Act
Identifying and Managing Risk of Modern Slavery
Our Policies on slavery and human trafficking
We do not tolerate any form of modern slavery or human trafficking in any part of our business. Our commitment to this coincides with all relevant UK employment laws and have internal policies in place to prevent slavery and human trafficking included in the employee handbook, which is circulated to all employees and covers recruitment, health & safety, harassment, anti-bribery, equal opportunities and diversity.
Our policies are developed within relevant departments following a process of stakeholder consultation, cross-departmental information sharing and senior management review and approval. Our policies provide a clear framework, which is communicated via the intranet, newsletters, eLearning, onsite training and emails.
We want to ensure that ESG risks and opportunities are managed and that our policies are implemented across our and locations and with our suppliers. Our parent company Captivate Group Limited provides ongoing support to encourage and facilitate
implementation of the policiea. In addition, our internal sustainability advisors are working with us to review implementation of our standards and to identify and address areas for improvement.
Due Diligence Processes for slavery and human trafficking in Our Business and Our Supply Chain
As part of our initiative to identify and mitigate risk we periodically review the effectiveness of our processes and systems and any changes will be reflected in future annual statements.
We conducted an internal risk assessment and given the nature of our business in this country and that most of our people are direct employees, we ascertained that the risk of trafficking or slavery amongst this category is very low.
Our main categories of spend include IT, travel, telecommunications, professional services and facilities and those used in client work, such as advertising production, market research and other marketing services.
Seen Connects manages the appointment of “approved suppliers”, where contracts are entered into. An “approved supplier” is defined as one that has been appointed following evaluation against assessment criteria, including risk, operational, commercial and sustainability considerations. We use “approved suppliers” for commonly purchased goods and services, whenever possible. In addition, we maintain a list of locally approved suppliers based upon the formal selection process outlined in our procurement policy. It is our responsibility to select, monitor and manage any suppliers that they use if they are not listed on our “approved supplier” list.
We are currently reviewing the existing procurement procedures to assess whether more extensive modern slavery considerations should be integrated into our due diligence process for working with suppliers.
Seen Connects has a programme which embeds our sustainability standards into our supply chain. The programme involves a variety of activities including assessment, onsite visits and awareness training that will allow us to identify any gaps relating to sustainability issues, including risks around modern slavery.
We issue guidance to our operating companies reiterating that we do not tolerate people trafficking or forced labour, and providing examples of risk areas. It is the responsibility of our operating companies to ensure that this is communicated to all employees within their operations.
Seen Connects is committed to maintaining high ethical standards, protecting human rights and acting with honesty and integrity in everything we do. We endeavour to understand where there are risks of modern slavery within any part of our business and supply chain so that we can address them appropriately and sustainably. We will continue to strive to maintain awareness and ensure a high level of understanding by our employees and suppliers of the risks of modern slavery and human trafficking in our business
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