Modern Slavery and Human Trafficking
Definition
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as
slavery, servitude, forced and compulsory labor and human trafficking, all of which have in common the
deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
Policy
Agilebydefault does not tolerate modern slavery or human trafficking in its organization or in its supply
chain. The company is committed to acting 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 supply chain.
Agilebydefault is also committed to ensuring there is transparency in its business and its approach to
tackling modern slavery throughout its supply chain, consistent with its disclosure obligations under the
Modern Slavery Act 2015. Agilebydefault expects the same high standards from its contractors,
suppliers, and other business partners, and as part of its contracting processes includes specific
prohibitions against the use of forced, compulsory or trafficked labor, or anyone held in slavery or
servitude, whether adults or children. Agilebydefault expects its suppliers will hold their suppliers to the
same high standards.
Agilebydefault Supply Chain
Agilebydefault supply chain includes:
• Recruitment agencies and suppliers of contract IT resources
• Suppliers of IT equipment, software and services
• Professional services from lawyers, accountants and other advisers
• Office cleaning and other office facilities services
• Print and promotional material production
• Marketing and PR services
Applicability
This policy applies to everyone working for Agilebydefault or on its 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 any
time.
Responsibility
The Agilebydefault Board is responsible for ensuring this policy complies with Agilebydefault’ legal and
ethical obligation, and that all those under its control comply with it.
Divisional Directors are responsible for ensuring compliance in their Divisions and for their supplier
relationships. They have 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.
Employees are responsible for ensuring they are familiar with employee policies and guidelines relating
to modern slavery and complete any associated compliance training.
Compliance
The prevention, detection and reporting of modern slavery in any part of Agilebydefault’ business or
supply chains is the responsibility of all those working for Agilebydefault or under its control. Any
activity that might lead to, or suggest, a breach of this policy is not permitted.
If you believe or suspect a breach of this policy has occurred in any part of Agilebydefault’ business or
supply chain, or that it may occur, you must notify your manager or report it in accordance with the
Whistleblowing Policy as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their
working conditions in our supply chain constitutes any of the various forms of modern slavery, consult
your manager.
Agilebydefault encourages openness and will support anyone who raises genuine concerns in good faith
under this policy, regardless of the outcome. The company is committed to ensuring no one suffers any
detrimental treatment (including dismissal, disciplinary action, threats or other unfavorable 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 Agilebydefault or its supply chain. If you believe that you have suffered any
such treatment, you should inform a Director immediately. If the matter is not remedied, and you are an
employee, you should raise it formally using the Grievance Procedure.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes
Agilebydefault’ slavery and human trafficking statement for the current financial year