SLAVERY AND HUMAN TRAFFICKING POLICY
1. POLICY STATEMENT
1.1. Modern slavery, encompassing slavery, servitude, forced labor, and human trafficking, is a grave violation of human rights and a criminal act. It involves depriving individuals of their liberty for personal or commercial exploitation. The Alternative Studio Limited (The Alternative) maintains a zero-tolerance stance on modern slavery and is committed to conducting its business ethically and with integrity. We are dedicated to implementing effective systems and controls to ensure that modern slavery is not present in our operations or supply chains.
1.2. The Alternative is devoted to transparency in addressing modern slavery within our organization and supply chains, as mandated by the Modern Slavery Act 2015. We expect the same high standards from all contractors, suppliers, and business partners. Our contracting processes incorporate explicit prohibitions against forced labor, compulsory labor, human trafficking, slavery, and servitude, for both adults and children. We anticipate that our suppliers uphold these same high standards with their own suppliers.
1.3. This policy applies to all individuals working for The Alternative, including employees, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
1.4. This policy does not constitute a part of any employee's employment contract and may be amended at any time.
2. RESPONSIBILITY FOR THE POLICY
2.1. The board of directors holds ultimate responsibility for ensuring this policy aligns with our legal and ethical obligations and that all parties under our control comply with it.
2.2. The Finance and Office manager assumes primary responsibility for implementing this policy, monitoring its usage and effectiveness, addressing queries, and auditing internal control systems to ensure they effectively counter modern slavery.
2.3. Management at all levels must ensure that those reporting to them understand and adhere to this policy. Adequate and regular training on this policy and the issue of modern slavery in supply chains is provided.
2.4. Feedback and suggestions for policy improvement are welcomed and should be directed to the compliance manager.
3. COMPLIANCE WITH THE POLICY
3.1. All individuals must read, comprehend, and comply with this policy.
3.2. The prevention, detection, and reporting of modern slavery are the responsibilities of everyone working for The Alternative. All personnel are required to avoid activities that could lead to or suggest a breach of this policy.
3.3. If any person believes or suspects a conflict with this policy has occurred or may occur, they must promptly notify their manager or the compliance officer.
3.4. Early reporting of concerns about modern slavery within our business or supply chains is encouraged.
3.5. Suspected or actual breaches of this policy must be reported as soon as possible, following our Whistleblowing Policy.
3.6. If unsure about whether a specific act or working conditions within any tier of our supply chains constitute modern slavery, individuals should consult with their manager or the compliance officer.
3.7. The Alternative promotes an environment of openness and supports anyone who raises genuine concerns in good faith, even if these concerns prove unfounded. We are committed to ensuring that no one faces detrimental treatment as a result of reporting their suspicion of modern slavery taking place within our business or supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or any other adverse actions connected to raising a concern. Any individual experiencing such treatment should immediately inform the compliance manager and, if necessary, use our Grievance Procedure.
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1. Training on this policy and the risks of modern slavery in our supply chains is included in the induction process for all individuals working for The Alternative. Regular training will be provided as needed.
4.2. Our zero-tolerance stance on modern slavery is communicated to all suppliers, contractors, and business partners at the outset of our relationship with them and reinforced as appropriate.
5. BREACHES OF THIS POLICY
5.1. Employees found in breach of this policy will face disciplinary action, which may result in dismissal for misconduct or gross misconduct.
5.2. The Alternative may terminate relationships with individuals and organizations working on our behalf if they breach this policy.