modern slavery & human trafficking statement.

What is a Modern Slavery and Human Trafficking Statement?

Modern slavery and human trafficking can occur in any country, area or industry, including in the UK and Vivid (“We” “Our”) is committed to preventing it from occurring in Our business activities. It is a crime and We take a zero-tolerance approach in relation to it and will uphold all applicable and relevant laws and regulation to eradicate it. We currently operate in the UK only.

We aim to act in a transparent way, with integrity, ethically and fairly in all of Our business dealings with those up and down the supply chain. We aim to have effective processes and procedures in place which are enforced to ensure that modern slavery and human trafficking is not present in Our business or the business of those that We deal with. We expect and require those We deal with to do the same in their own business and supply chain. This is a contractual requirement.

This statement sets out the steps We have put in place to achieve this, Our expectations and the responsibilities of Our staff and third parties. It also provides guidance and information for those We work with recognise and address issues to achieve Our aim of ensuring that there is no slavery or human trafficking in Our own business and supply chains. 

What period this Modern Slavery and Human Trafficking Statement cover?

It relates to actions and activities during the financial year April 2023 to April 2024.

Are there any words that I need to know the meaning of before I start? 

Yes, there are. In this Modern Slavery and Human Trafficking Statement, unless the context otherwise requires, the following term shall have the following meaning:

What happens if you commit Modern Slavery and Human Trafficking?

Modern slavery and human trafficking is a crime and if We fail to prevent it in Our business and supply chain, We can face criminal sanctions. Such sanctions could include exclusion from public contracts, imprisonment of individuals and unlimited fines. It would also damage Our reputation and could lead to loss of Our business.

What does this Statement cover?

This statement covers the risks We have identified in Our organisational structure, supply chains and Our business activities. The following activities are considered to be at high risk of modern slavery or human trafficking: 

1. Provision of fraudulent identification documents for employees such as passports, work permits or visa’s;
2. Fake candidates whereby a different person from the candidate undertakes work designated to the candidate;
3. Payment to third parties that should be paid to the candidate.

Who is responsible for this Modern Slavery and Human Trafficking Statement?

The director has overall responsibility for Our anti-slavery initiatives and must ensure that Our obligations, legal and ethical, are complied with. The director must also ensure that all of those that this Statement applies to, comply with it and uphold Our ethos in relation to modern slavery and human trafficking.

In addition to the director, the compliance manager oversees and is responsible for the day-to-day implementation of Our processes and procedures to identify and eradicate modern slavery and human trafficking. This includes creating, reviewing     and implementing policies and procedures, monitoring the effectiveness and suitability and identifying changes required to keep up to date and maintain that effectiveness.  The compliance manager will also conduct risk assessments in relation to modern slavery and human trafficking of any processes and procedures introduced and relationships entered into. 

All management have a duty to ensure that their teams are trained and understand the risks of and what is expected from them, in relation to modern slavery and human trafficking. This includes the requirement to obtain suitable documentation in relation to contractor candidates and to conduct due diligence in relation to suppliers and customers. Management is required to monitor compliance and highlight any issues identified to the compliance manager. 

We all have a duty to be alert to risks, however small. We encourage, expect and require all workers and third parties to report any concerns related to Our direct activities or supply chains and management are expected and required to act upon them.

What training takes place in relation to Modern Slavery and Human Trafficking?

To ensure a good understanding of the risks of modern slavery and human trafficking in Our business and supply chains, all of Our staff and workers are trained to identify modern slavery and human trafficking, during their induction with us. This is supported with regular update training, annually as a minimum, with additional training, as necessary, for those identified as being at a higher risk of exposure to relevant activity as part of their role. 

How do you assess and monitor your supply chains? 

We undertake due diligence when considering taking on new suppliers, and regularly reviews Our existing suppliers. Our due diligence process includes identifying the parties involved, building long-standing relationships with suppliers, making clear Our expectations of third parties, evaluating the modern slavery and human trafficking risks of each new supplier. We require suppliers to comply with applicable laws and regulations in relation to modern slavery and human trafficking and where any issues arise or are identified, We will bring this to the attention of the supplier and require it to be addressed to meet required standards. We may then invoke sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

How do you review the effectiveness of your Modern Slavery and Human Trafficking prevention measures?

We use key performance indicators to measure how effective We are in preventing modern slavery and human trafficking taking place in Our business and/or supply chains.

• We monitor Our payroll systems to ensure that payments are made to an account in the name of the employee undertaking the work
• We provide National Living Wage or National Minimum Wage, as appropriate and require suppliers up and down the supply chain to do the same.
• We provide access to full employment rights for workers and require suppliers up and down the supply chain to do the same. 
• We check and cross reference ID documentation with customers, referrers and government records, as appropriate.

Do you make changes to this Modern Slavery and Human Trafficking statement? 

Yes, it is reviewed and updated at least annually and more frequently if required if, for example, the level of risk and/or the law changes. The director approves, authorizes and endorses this policy statement and is fully committed to its implementation.