Modern Slavery Statement

This statement sets out the Company’s actions aimed at taking measures to prevent slavery or human  trafficking in its business and supply chain. The Company is committed to improving its practices to combat  slavery and human trafficking. This statement is made pursuant to section 54(1) of the Modern Slavery Act  2015 (the “Act”) and constitutes the Company’s slavery and human trafficking statement in relation to its  actions and activities during the financial year 1 January 2022 to 31 December 2022. 

Organizational structure and business 

The Company acts as an advertising agency both for domestic and international clients producing marketing  assets for broadcast, digital and print channels.  

Our Supply Chains 

The Company’s supply chains include production companies, software developers, I.T. and other office  equipment, professional services, office cleaning and other office facilities services. We are based in the UK and Sri Lanka and the majority of our suppliers and our supply chain is low risk and non-complex in structure as we are a start up company. 

Our policies on slavery and human trafficking 

Our position on slavery and human trafficking is clear as we have current established policies, processes and  practices in place to prevent this within our business operations and supply chains. We continuously look at  ways to enhance these processes and we currently undertake the following measures: 

It is now our policy to require our suppliers to adhere with our supplier code of conduct (the “Code”) which  amongst other governance and compliance obligations made reference to in the Act, sets out the minimum  behaviors, standards and practices we expect to see from our suppliers and amongst other obligations  prohibits forced labor, discrimination and child labor, ensures supplier working conditions are safe and that  workers are treated with respect and dignity with the aim of preventing slavery and human trafficking taking  place anywhere in our supply chains or business operations.  

Our Purchase Order Terms and Conditions and Global Supplier Agreements contract terms require our  suppliers and vendors to comply with all applicable law and have recently been updated to include compliance  with the Act and Code. 

We practice responsible procurement. Contracts signed with major suppliers central or regional are  encouraged to mobilize in favour of human rights through our internal ‘CSR Procurement Charter’ and ‘CSR  Procurement Questionnaire’ which are sent to all suppliers during the tendering process. Suppliers are also  sent CSR Procurement guidelines and their actions, commitment to CSR is a must. 

environment, ethics etc. so that we can measure and monitor the suppliers progress and achievements with  our compliance policies.

We comply with all relevant UK employment laws and have internal policies in place to prevent slavery and  human trafficking. 

Risk Assessment and Due Diligence 

With the introduction of the Act, we assessed our supply chain for potential areas of increased risk of slavery  and human trafficking. As part of our initiative to identify and mitigate the risk of slavery and human  trafficking in our supply chains, we conduct reviews of our major suppliers and identified those in high-risk  areas. 

We ask our existing and new suppliers to complete a self-assessment questionnaire detailing any action,  procedures, policies and practices carried out by their organization to prevent slavery and human trafficking.  Suppliers must agree to adhere to the Code, a copy which is attached to the questionnaire and they are also  required to annually certify a declaration form confirming understanding and compliance with the Code and the Act. 

High-risk suppliers will get a more detailed review of their questionnaires to identify areas of concern that may  conflict with our Code or the Act, better understand the risk, provide feedback and agree steps to put in place  to improve their processes. High-risk suppliers that will receive special attention include companies that  operate using temporary low skilled workers, operate outside the UK or EEA and/or manufacture or trade in  raw materials outside the UK or EEA. 

We will continually assess our compliance with the Act through the mechanisms of an annual audit carried out  by our legal, procurement and internal audit teams. 

Further Steps 

We will periodically review the effectiveness of our processes and systems and any changes will be reflected in  future annual statements. 

This statement has been approved by the board of directors of the Company.