Modern Slavery Policy

What is Modern Slavery? 

Modern slavery is the illegal exploitation of other people for personal or commercial gain. There are varying types including Human Trafficking and Forced labour. Further information on Modern Slavery can be found on the Anti-Slavery International Charity’s website

The most common forms of modern slavery are as follows: 

  • –  Human trafficking: The use of violence, threats or coercion to transport, recruit or harbour people in order to exploit them for purposes such as forced prostitution, labour, criminality, marriage or organ removal. 
  • –  Forced labour: Any work or services people are forced to do against their will under threat of punishment. 
  • –  Debt bondage/bonded labour: The world’s most widespread form of slavery. People trapped in poverty borrow money and are forced to work to pay off the debt, losing control over both their employment conditions and the debt. 
  • –  Descent–based slavery: Most traditional form, where people are treated as property, and their “slave” status was passed down the maternal line. 
  • –  Slavery of children: When a child is exploited for someone else’s gain. This can include child trafficking, child soldiers, child marriage and child domestic slavery. 

Products of Change has a not-for-profit membership organisation, The Products of Change Alliance, at the core of our operations, with a for profit consultancy and media arm ‘Products of Change Media Ltd’.  We partner with Max Media Ventures for our business supporting functions and media arm. 

We exist to support the brand and licensing industry (brand owners, manufacturers, retailers and supporting functions) on its journey to reduce its environmental impact.  We deliver this through education modules, research, best practice sharing, events, workshops and collaborating to build the infrastructure of tomorrow. 

Products of Change Media Ltd Purchases 

  • Printing
  • Web development
  • Creative Services
  • Consultancy

Operating across multiple geographies globally. 

Our policies 

This Modern Slavery policy highlights that 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 supply chains. 

Products of Change Media Ltd is fully committed to human rights in the workplace as shown in our Human Rights Policy and this extends to our zero tolerance approach to modern slavery, in all forms that it takes

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. As part of this commitment, we expect the same high standards from all of our contractors, suppliers and other business partners. 

To further highlight the commitment we take at Products of Change Media Ltd and across our supply chain to tackle Modern Slavery, we have the following policies and processes currently running in our company: 

  • –  Code of Conduct – sets out what we expect from every single person working for and with Products of Change Media Ltd. It also underlines our responsibilities to our people, partners and shareholders. 
  • –  Anti-Bribery – sets out the responsibilities of both Products of Change Media Ltd and our partners in regard to observing and upholding our zero-tolerance positions on bribery and corruption 
  • –  Whistleblowing – we have implemented a process where employees can anonymously report legitimate concerns with the business and our supply chain. More details of this are made available to all our employees via our web site.  
  • –  Supplier Code of Conduct – all suppliers are to now sign this code before we commence proceedings with them (and all suppliers whom we had contracted prior to this implementing this code have since signed). Part of this code highlights are expectations on how a supplier treats their employees and their support for the protection of internationally proclaimed human rights, fight forced labour (including modern slavery and human trafficking) and child labour. 
  • –  Human Rights Policy – this lays out are commitment to human rights in the workplace, respecting the dignity and worth of all employees, and our zero tolerance approach to child labour and modern slavery. 

Who does this policy apply to?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners. 

This policy does not form part of any employee’s contract of employment and we may amend it at any time. 

Our Due Diligence 

When contracting with new and existing suppliers, they are required to sign and adhere to 

our Supplier Code of Conduct to confirm that they also operate a zero-tolerance approach to 

exploitation and actively request that all our new suppliers/contractors comply to the 

requirements of the Modern Slavery Act 2015. If we become aware of any breaches, then 

we will make it clear to our suppliers and contractors that we will terminate contractual terms 

as a result of the breach. 

We have specific commitments on preventing child labour, promoting labour rights in 

agricultural supply chains and helping to ensure good conditions of work and employment. 

We monitor suppliers’ compliance with our requirements through initiatives including third-party audits, independent assessments, and contractual and relationship reviews.

The effectiveness of our approach 

All suppliers and contractors are evaluated and are required to complete a questionnaire, 

this information is assessed and all approved suppliers and contractors and added to our 

approved suppliers’ databases.

 

Our training for employees 

Upon joining Products of Chane Media Ltd we will notify you on the existence of this policy, as well as on the risk our business faces from modern slavery in its supply chains. We will ensure you have adequate training to spot any suspicious activity that may be regarded as modern slavery, and ensure you are aware of the correct procedure to follow if this occurs – as indicated above. Any updates will be provided using established methods of communication between Products of Change Media Ltd and you, and to ensure familiarity with this policy, we share the our Modern Slavery policy on an annual basys with all employees. 

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. 

What occurs in a Breach of Policy? 

Any employee who breaches this Policy by engaging in or conspiring to engage in any Modern Slavery conduct will face disciplinary action. This could, in the most severe circumstances include immediate dismissal for misconduct or gross misconduct and, if warranted, legal proceedings may be brought against the employee under the Modern Slavery Act 2015. 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy, and again, if warranted, legal proceedings may be brought against the individual/company in question under the Modern Slavery Act. 

How can I comply? 

You must ensure that you read, understand and comply with this policy. 

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 line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. 

We encourage you to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier 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 line manager OR company Director OR report it in accordance with our Whistleblowing Policy to be found on the internal intranet site as soon as possible. 

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains. 

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 line manager or company 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 supply chains. 

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 line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our “Grievance Process”.

Who is responsible? 

Products of Change Media Ltd has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. 

Products of Change Media Ltd has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. 

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training (this training will be organised by us, Products of Change Media Ltd on it and the issue of modern slavery in supply chains. 

As always, we open our doors and actively encourage you to comment on this policy and suggest ways in which it might be improved. For any comments, suggestions and/or queries on the Modern Slavery policy to please reach out to Helena Mansell-Stopher, CEO. 

This policy and statement relates to the financial year 2024 and is updated on an annual basis
statement is approved by Helena Mansell-Stopher, CEO.

Anti-Bribery & Anti-Corruption Policy 

Contents 

  • What does your policy cover? …………………………………………………………………….. 3 
  • Policy statement ………………………………………………………………………………………… 3 
  • Who is covered by the policy? ………………………………………………………………… 3-4 
  • Definition of bribery………………………………………………………………………………….4 
  • What is and what is not acceptable ……………………………………………………….. 4-6 
  • Gifts and hospitality…………………………………………………………………….4-5 
  • Facilitation payments and kickbacks…………………………………………..5-6 
  • Political contributions……………………………………………………………………..6 
  • Charitable contributions …………………………………………………………………6 
  • Employee Responsibilities …………………………………………………………………………. 6 
  • What happens if I need to raise a concern……………………………………………… 7-8 
  • How to raise a concern ………………………………………………………………….7 
  • What to do if you area victim of bribery or corruption………………..7 
  • Protection ………………………………………………………………………………….7-8 
  • Training and communication ……………………………………………………………………… 8 
  • Record Keeping…………………………………………………………………………………………… 8 
  • Monitoring and reviewing ………………………………………………………………………….. 8 


  • What does your policy cover? 

1.1 This anti-bribery policy exists to set out the responsibilities of Products of Change Media Ltd and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption. 

1.2 It also exists to act as a source of information and guidance for those working for Products of Change Media Ltd.  It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities. 

  • Policy statement 

2.1 Products of Change Media Ltd is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented.  Products of Change Media Ltd has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate. 

2.2 [Products of Change Media Ltd will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad. 

2.3 Products of Change Media Ltd recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously. 

  • Who is covered by the policy? 

3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level. 

3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties. 

3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply.

  • Definition of bribery 

4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. 

4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. 

4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. 

4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager. 

  • What is and what is NOT acceptable 

5.1 This section of the policy refers to 4 areas: 

  • Gifts and hospitality. 
  • Facilitation payments. 
  • Political contributions. 
  • Charitable contributions. 

5.2 Gifts and hospitality 

Products of Change Media Ltd accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements: 

  • It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits. 
  • It is not made with the suggestion that a return favour is expected. 
  • It is in compliance with local law. 
  • It is given in the name of the company, not in an individual’s name. 
  • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate). 
  • It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion). 
  • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift. 
  • It is given/received openly, not secretly. 
  • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them. 
  • It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100). 
  • It is not offer to, or accepted from, a government official or representative or  politician or political party, without the prior approval of the company’s compliance manager. 

5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances. 

5.4 Products of Change Media Ltd recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. 

5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed. 

5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought. 

5.7 Facilitation Payments and Kickbacks 

Products of Change Media Ltd does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action. 

5.8 [Products of Change Media Ltd does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage. 

5.9 Products of Change Media Ltd recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken: 

  • Keep any amount to the minimum. 
  • Ask for a receipt, detailing the amount and reason for the payment. 
  • Create a record concerning the payment. 
  • Report this incident to your line manager. 

 

5.10 Political Contributions 

Products of Change Media Ltd will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage. 

5.11 Charitable Contributions 

Products of Change Media Ltd accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes. 

5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. 

5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager. 

  • Employee Responsibilities 

6.1 As an employee of Products of Change Media Ltd, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given. 

6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. 

6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager. 

6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. [A Managing Director has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy. 

  • What happens if I need to raise a concern? 

7.1 This section of the policy covers 3 areas: 

  • How to raise a concern. 
  • What to do if you are a victim of bribery or corruption. 
  • Protection. 

7.2 How to raise a concern 

If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Products of Change Media Ltd, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal. 

7.3 [Products of Change Media Ltd will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially. 

7.4 What to do if you are a victim of bribery or corruption 

You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity. 

7.5 Protection 

If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Products of Change Media Ltd understands that you may feel worried about potential repercussions. [Products of Change Media Ltd will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken. 

7.6 [Products of Change Media Ltd will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. 

7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised. 

7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately. 

  1. Training and communication 

8.1 [Products of Change Media Ltd will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy. 

8.2 [Products of Change Media Ltd’’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter. 

8.3 [Products of Change Media Ltd will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti- bribery training where there is a potential risk of facing bribery or corruption during work activities. 

  • Record keeping 

9.1 Products of Change Media Ltd will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review. 

  • Monitoring and reviewing 

10.1 Products of Change Media Ltd compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness. 

10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice. 

10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager. 

10.4 This policy does not form part of an employee’s contract of employment and [Products of Change Media Ltd may amend it at any time so to improve its effectiveness at combatting bribery and corruption. 

 

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