Modern slavery and human trafficking policy
Purpose
This policy sets out St Luke’s commitment to ensure compliance with the Modern Slavery Act 2015 (“the Modern Slavery Act” or “the Act”).
It provides guidance to all staff, clients and suppliers as part of the compliance with Modern Slavery
legislation, to ensure that all directors, managers, employees or third party agents adhere to the Act.
Organisational Structure & Supply Chain.
St Luke’s is a creative advertising agency operating in the UK. We provide creative, strategic, and
production services to consumer-facing brands. Our operations are office-based and primarily involve creative services carried out by employees and freelance partners. Our supply chains mainly consist of:
● Creative production vendors (e.g., photography, film, animation, post-production)
● Freelancers and independent contractors
● Technology and software providers
● Office suppliers and facilities services
● Professional services (e.g., legal, finance, HR support)
Although our supply chains are relatively low risk compared to manufacturing or logistics sectors, we
recognise that labour exploitation can occur in any industry. We therefore expect all suppliers and
partners to adhere to the same high standards we set for ourselves.
Policy Statement
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. 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 suppliers.
We are also committed to ensuring there is transparency in our own business and in our approach to
tackling modern slavery throughout our suppliers, 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.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion
As an equal opportunities employer, we're committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.
Due Diligence
We conduct due diligence on suppliers and partners to minimise the risk of modern slavery within our
supply chains. Our due diligence processes include:
● Including contractual clauses prohibiting forced labour, human trafficking, and exploitative
practices.
● Reviewing new suppliers before onboarding, especially those involved in production or
labour-intensive services.
● Monitoring ongoing supplier relationships to ensure continued compliance.
● Investigating concerns raised by employees or partners about supplier practices.
● Where concerns are identified, we take appropriate action, which may include terminating the
supplier relationship.
Risk Assessment
We assess modern slavery risks across our supply chain by considering: The nature of services provided (e.g., production services may involve temporary labour or overseas work). Geographic risks where suppliers or subcontractors operate outside of the UK. The level of direct control we have over supplier practices. Supplier size and sector, including whether they operate in industries with known
labour-exploitation risks.
Risk management actions include:
● Prioritising higher-risk suppliers for review.
● Requesting evidence of modern slavery compliance where appropriate.
● Addressing risks promptly through communication, corrective actions, or changes in supplier
arrangements.
We aim to maintain transparent and long-term relationships with suppliers who share our ethical
commitments.
Procedures
As an organisation operating in the UK, St Luke’s must be aware of, and ensure its compliance with, the Modern Slavery Act.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager or a Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or suppliers at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or a Director or report it in accordance with our Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or a Director.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of
whatever form is or may be taking place in any part of our own business or in any of our suppliers.
Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager or a Director immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in our Handbook.
Responsibility for Adoption and Implementation by St Luke’s
This Modern Slavery and human trafficking Policy require all St Luke’s staff to:
● read and understand the mandates set out in it;
● comply with the mandates.
● report immediately actual or suspected violations to your manager or a Director
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for
misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
Training & Awareness
We provide training and guidance to staff to ensure they understand the risks of modern slavery and howto respond to concerns. This includes:
● Induction for all new employees on our Modern Slavery Policy and reporting procedures.
● Clear communication channels for reporting concerns safely and confidentially.
Our aim is to ensure that all staff can recognise potential issues and feel confident to report them.
Key Performance Indicators
To measure the effectiveness of our approach to preventing modern slavery, St Luke’s monitors the
following KPIs annually:
● Percentage of new suppliers reviewed for modern slavery compliance during onboarding.
● Number of modern slavery concerns raised and resolved (we expect this number to be low but take
all reports seriously).
● Frequency of policy reviews (with a minimum of one review per year).
These indicators help us assess whether our policies and processes remain effective and identify areas for improvement.
Where To Get Help
If you have any questions about this Modern Slavery and human trafficking Policy, please reach out to your manager. If you believe that the Modern Slavery and Human trafficking Policy may have been
violated, you should immediately contact your manager, our HR Lead or a Director.
Approval & Ownership
St Luke’s is committed to preventing modern slavery and human trafficking in all areas of our business and supply chain, in accordance with the Modern Slavery Act 2015.
This policy has been formally adopted by St Luke’s and will be reviewed annually, or sooner if required by changes in legislation or organisational practice.
