Modern Slavery Policy

Modern slavery includes:

• Human trafficking.
• Slavery and servitude.
• Forced labour and forced marriage.
• Debt bondage.
• Deceptive recruiting for labour or services.
• The worst forms of child labour, including exploitation and hazardous work.

2. Who this applies to

This policy applies to Digital Guppy, employees, contractors and subcontractors. We also expect our suppliers and business partners to uphold these standards, including those providing digital services, hosting, software and equipment.

3. Our approach

We will not knowingly engage people or suppliers whose work relies on exploitation. Work must be freely chosen, with lawful pay and conditions and no coercion, recruitment debts or withholding of identity documents.

We will consider modern slavery risks when choosing and reviewing suppliers. Checks will reflect the type of work and the level of risk. Where appropriate, we may ask for:

• Information about who performs the work and any subcontractors involved.
• Relevant employment practices and modern slavery policies or statements.
• Evidence of how identified risks are being addressed.

We will raise concerns with suppliers and seek appropriate commitments in our agreements.

4. Raising a concern

Anyone concerned about exploitation connected with our business or suppliers can email [email protected]. Digital Guppy will review the concern. You do not need proof before reporting it.

We will treat reports sensitively and will not retaliate against anyone who raises a concern honestly. You may also report concerns directly to the relevant authorities, including where a concern involves Digital Guppy.

5. Responding to breaches

We will assess concerns and take appropriate action, prioritising the safety of affected people. Where a supplier is involved, we will seek corrective action within an agreed timeframe and check progress.

Breaches by employees may result in disciplinary action. Breaches by contractors or suppliers may result in work being suspended or the relationship ending, subject to applicable law and contract terms. We will consider the impact on affected workers and support appropriate steps to put harm right.