Policy Reference: DOC11

Version: 1.0

IS Classification: Public

Date: 01/07/2021

Owner: Managing Director

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Introduction

This statement sets out Central Fieldwork’s actions to understand all potential modern slavery risks
related to its business and to put in place steps that are aimed at ensuring that there is no slavery or
human trafficking in its own business and its supply chains.

We recognise that we have a responsibility to take a robust approach to slavery and human trafficking
and we continue to take our responsibility very seriously.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate
activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Central Fieldwork Limited.

• Central Fieldwork is a market research agency which recruits great people to collect & analyse
data that represents the real views of Britain.

Countries of operation and supply

We currently operate in the following countries:

• We have offices in Leeds, and London, employing a team of Market Research Recruitment
professionals, delivering the services listed above. We mainly operate in the UK, however some
of our clients do trade globally and we may be asked to conduct recruitment in other countries.

The following is the process by which the company assesses whether particular activities or countries
are high risk in relation to slavery or human trafficking:

• All suppliers are asked to provide copies of their Modern Slavery Policy/ Statement.

High-risk activities

We do not believe that any of the company’s activities to be at risk of slavery or human trafficking.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

Policies: The Managing Director is responsible for ensuring all employees adhere to the
policy and are informed of the company’s position regarding slavery and human trafficking.
The Operations Team, namely the Purchasing & Compliance Manager and the HR Manager
are responsible for the review and monitoring of this, in conjunction with the Managing
Director.
Risk assessments: We require all senior managers to carry out risk assessments of their
services to determine our risk exposure. We update our risk register to ensure that any risks
are appropriately flagged, mitigated, and monitored.
Investigations/due diligence: The Managing Director is responsible for ensuring that the
appropriate individuals are assigned for investigations and due diligence in relation to known
or suspected instances of slavery and human trafficking.
Training: The company will ensure that training takes place either directly within the
company, or with the suppliers and others, to better understand and respond to the identified
slavery and human trafficking risks.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery
risks and steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing policy We encourage all our workers, customers, and other business partners
to report any concerns related to the direct activities, or the supply chains of, our organisation.
This includes any circumstances that may give rise to an enhanced risk of slavery or human
trafficking. Our whistleblowing procedure is designed to make it easy for workers to make
disclosures, without fear of retaliation. Employees, customers, or others who have concerns can
[use our confidential helpline/complete our confidential disclosure form].
Employee code of conduct Our code makes clear to employees the actions and behaviour
expected of them when representing our organisation.
Supplier/Procurement code of conduct We are committed to ensuring that our suppliers
adhere to the highest standards of ethics. Suppliers are required to demonstrate that they
provide safe working conditions where necessary, treat workers with dignity and respect, and
act ethically and within the law in their use of labour. We work with suppliers to ensure that
they meet the standards of the code and improve their worker’s working conditions. However,
serious violations of our supplier code of conduct will lead to the termination of the business
relationship. As part of the supplier onboarding process, new suppliers are required to provide
a copy of their Modern Slavery Statement/ Policy.
Recruitment/Agency workers policy We use only specified, reputable employment agencies
to source freelance support or employees. It is rare that we do use freelance support however
when we do, we do consider this to be low risk due to the nature of the business activities.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly
reviews its existing suppliers. The organisation’s due diligence and reviews include:

• evaluating the modern slavery and human trafficking risks of each new supplier.

Training

We require everyone working within our organisation to complete training on modern slavery. The
training covers:

• how to assess the risk of slavery and human trafficking in relation to various aspects of the
business, including resources and support available.
• how to identify the signs of slavery and human trafficking.
• what initial steps should be taken if slavery or human trafficking is suspected.
• how to escalate potential slavery or human trafficking issues to the relevant parties within the
organisation.
• what external help is available, for example through the Modern Slavery Helpline,
Gangmasters and Labour Abuse Authority and “Stronger together” initiative.
• what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply
chains policies in high-risk scenarios, including their removal from our supply chains.

Awareness-raising programme

As well as training everyone, the organisation will raise awareness of modern slavery issues by putting
up posters across the organisation’s premises and posting this information on SharePoint. The
information explains to staff:

• the basic principles of the Modern Slavery Act 2015.
• how employers can identify and prevent slavery and human trafficking.
• what employees can do to flag up potential slavery or human trafficking issues to the relevant
parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline

Director approval

This statement was approved on 1st July 2021 by our Managing director who will review and update it
annually.

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