This statement is made on behalf of GWT Media Ltd pursuant to the section 54(1) of the Modern Slavery Act 2015 and comprises our slavery and human trafficking statement.

It outlines the steps we have taken as a business to identify and prevent slavery and human trafficking in our own operations and supply chains. We understand our responsibilities and are committed to improving our practices to combat slavery and human trafficking.

Policy Statement

1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. GWT Media Ltd has a zero-tolerance approach to modern slavery and is committed to acting
2. ethically and with integrity in all its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its own business or in any part of its supply chain.
3. GWT Media Ltd is also committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with disclosure obligations under the Modern Slavery Act 2015. ERS expect the same exacting standards from all its contractors, suppliers, and other business partners, and as part of its contracting processes, GWT Media Ltd includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and GWT Media Ltd expect that its suppliers will hold their own suppliers to the same exacting standards.
4. This policy applies to all people working for GWT Media Ltd or on its behalf in any capacity, including employees at all levels, directors, officers, interns, agents, contractors, external consultants, third-party representatives, and business partners.
5. This policy does not form part of any employee’s contract of employment

Responsibility

1. The directors of GWT Media Ltd have overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under its control comply with it.
2. The procurement and accounting teams have primary and day-to-day responsibility for implementing this policy and monitoring its use and effectiveness.
3. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

Compliance

1. The prevention, detection and reporting of modern slavery in any part of the business or supply chain is the responsibility of all those working for GWT Media Ltd or under its control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
2. Employees must notify their manager or the company directors as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.
3. Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chain of any supplier tier at the earliest possible stage.
4. If an employee believes or suspects that a breach of this policy has occurred or that it may occur a report must be made to the appropriate line manager or report must be made as soon as possible in accordance with the GWT Media Ltd Whistleblowing Policy which can be found in the staff handbook.
5. If an employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of the GWT Media Ltd supply chain constitutes any of the various forms of modern slavery, it must be raised with the appropriate line manager or company directors.
6. GWT Media Ltd aims 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. GWT Media Ltd is 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 the business or in any of GWT Media Ltd supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any member of staff believes that they have suffered any such treatment, they should inform the company directors immediately. If the matter is not remedied, the member of staff should raise it formally using our Grievance Procedure (found in the staff handbook).

Awareness and Communication

1. Appropriate training on this policy, and on the risk to the GWT Media Ltd business faces from modern slavery in its supply chains will be provided as necessary to targeted staff.
2. GWT Media’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of any business relationship with them and reinforced as appropriate thereafter.

Breaches

1. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
2. GWT Media Ltd may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.