1. Introduction
GM Marketing is committed to acting ethically, with integrity, and in compliance with all applicable laws relating to modern slavery and human trafficking. GM Marketing recognises its responsibility to take a robust approach to preventing slavery, servitude, forced labour, compulsory labour, and human trafficking in all areas of the business and supply chain.
This Modern Slavery and Human Trafficking Policy is intended to provide clarity and direction on how GM Marketing will identify, prevent, and respond to potential modern slavery risks.
GM Marketing is committed to ensuring that all employees, contractors, suppliers, and business partners are treated fairly, lawfully, and with dignity and respect.
This policy supports the organisation’s obligations under the UK Modern Slavery Act 2015.
2. Aims and Objectives
a. Aims
This policy aims to ensure that managers and employees recognise their responsibility to:
- understand what modern slavery and human trafficking are and how they may affect individuals and organisations;
- raise awareness and understanding of modern slavery risks within the workplace and supply chain;
- ensure a consistent approach in the management of any concerns relating to exploitation or unethical labour practices;
- reduce the risk of modern slavery occurring within the organisation or associated supply chains;
- foster an environment in which employees can openly and comfortably raise concerns relating to unethical conduct or exploitation.
b. Objectives
The aims of the Policy will be achieved through the following objectives:
- Provide a clear definition of modern slavery, forced labour, servitude, and human trafficking.
- Provide guidance on identifying and reporting concerns.
- Outline the responsibilities of managers, employees, suppliers, and contractors.
- Promote ethical business practices and due diligence procedures.
3. Policy Statement
Modern slavery and human trafficking are serious criminal offences and violations of fundamental human rights. GM Marketing has a zero-tolerance approach to modern slavery in any form.
GM Marketing recognises that risks can exist within supply chains and outsourced services and is committed to taking reasonable and proportionate steps to identify and address those risks.
GM Marketing is committed to ensuring that all individuals are treated fairly and with dignity and respect in their working environment.
The organisation is also committed to ensuring the health, safety, and wellbeing of the workforce and promoting ethical and lawful employment practices.
4. Definitions and Background
Modern slavery is an umbrella term used to describe serious exploitation. It includes:
- Slavery · Servitude
- Forced or compulsory labour
- Human trafficking
- Child labour
- Debt bondage
Human trafficking involves arranging or facilitating the movement of another person with a view to exploitation.
Forced labour occurs where individuals are coerced into work through threats, intimidation, abuse, violence, debt, or manipulation.
Modern slavery can affect individuals of all ages, genders, nationalities, and backgrounds. It can occur in legitimate businesses and supply chains both nationally and internationally.
GM Marketing recognises the importance of vigilance and responsible business conduct in reducing the risk of exploitation.
5. Scope of Policy
This policy applies to ALL GM Marketing employees.
This policy also applies to:
- Directors and senior managers
- Temporary workers and agency staff
- Contractors and consultants
- Freelancers and volunteers
- Suppliers, subcontractors, and business partners
All individuals working with or on behalf of GM Marketing are expected to comply with this policy.
6. Responsibilities
6.1 GM Marketing Board
The role of the GM Marketing Board is to take corporate responsibility for ensuring the organisation is able to deliver on the implementation of this Policy.
6.2 Human Resources
Human Resources will provide strategic leadership, direction and oversight of this Policy and its implementation.
6.3 Managers
The Board requires all managers within GM Marketing to implement and monitor the Policy within their area of responsibility.
Managers should:
• promote awareness of modern slavery risks; · ensure employees understand how to raise concerns; · support employees who report concerns; · monitor supplier and contractor relationshipswhere appropriate; · escalate concerns appropriately.
Managers do not need to be experts on modern slavery but should have a level of knowledge and understanding around how to identify warning signs and support staff.
6.4 Employees
Employees are required to familiarise themselves with this Policy and comply with its provisions.
Employees should:
- conduct business ethically and responsibly;
- report any concerns relating to exploitation or unethical practices;
- cooperate with investigations where required;
- treat colleagues and external parties with dignity and respect.
If employees find that they are unable to speak to their manager, they can contact Human Resources at hr@gmmarketing.co.uk.
7. Identifying Potential Indicators of Modern Slavery
Potential indicators may include:
- individuals appearing fearful, withdrawn, or controlled;
- poor working or living conditions;
- restricted freedom of movement;
- withholding of identification documents;
- excessive working hours;
- signs of physical abuse or intimidation;
- individuals being paid below legal minimum wage;
- concerns raised regarding unethical supplier practices.
Any concerns should be reported immediately.
8. Supplier Expectations and Due Diligence
- GM Marketing expects all suppliers, contractors, and business partners to:
- comply with the Modern Slavery Act 2015;
- prohibit forced labour, child labour, and human trafficking;
- ensure fair pay and lawful working conditions;
- maintain safe and respectful workplaces;
- operate ethically and transparently.
GM Marketing may undertake reasonable due diligence measures including:
- reviewing suppliers before engagement;
- assessing potential risks in supply chains;
- requesting confirmation of compliance where appropriate;
- addressing concerns identified through internal or external information.
Where serious concerns arise, GM Marketing reserves the right to terminate relationships with suppliers or contractors that fail to meet expected standards.
9. Reporting Concerns
Employees and external parties are encouraged to report any concerns relating to modern slavery, unethical conduct, or exploitation.
Concerns should be raised with:
- A line manager
- A company director
- Human Resources
Reports will be treated seriously and, where possible, confidentially.
No employee will suffer retaliation for raising a genuine concern in good faith.
10. Training and Awareness
GM Marketing will seek to ensure that relevant staff understand:
- what modern slavery is;
- how to identify warning signs;
- how to report concerns appropriately;
- the organisation’s responsibilities under the Modern Slavery Act 2015.
Awareness may be supported through onboarding materials, policy distribution, or periodic training.
11. Monitoring and Reviewing the Policy
It will be the responsibility of the nominated Director to ensure the Policy is implemented.
This policy shall be reviewed:
- Every 2 years or;
- following receipt of new information or legal guidance;
- upon implementation of new agreements which may affect the procedure.