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Modern Slavery and Human Trafficking Policy
for Oriel Studios Digital Limited

Effective Date: 22nd August 2025

Contents:

1.       What is the purpose of the policy?

2.      Policy Details

2.1.   Responsibility

2.2   Compliance

2.3   Breaches

2.4   Addressing Modern Slavery and Human Trafficking

2.5   Communications and Awareness

3.      Legislative or other guidelines.

  1. What is the purpose of this Policy?

1.1. 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. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

 

1.2 Any “commercial organisation” in any sector carrying on a business in the UK with a total annual turnover of £36 million or more is required to produce a slavery and human trafficking statement for each financial year however, this does not apply to Oriel Studios as we have a current projected turnover of £1.5 million for 2025 and growing in 2026.

 

1.3 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners.

 

1.4 This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.

 

1.5 This policy does not form part of any employee’s contract of employment and we may amend it at any time.

  1. Policy Details
2.1 Responsibility

 

 

2.1.1 The Board has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

 

2.1.2 The office manager has 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.

 

2.1.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

2.2 Compliance

 

2.2.1 You must ensure that you read, understand and comply with this policy.

2.2.2 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

 

2.2.3 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify the office Manager marcus@orielstudios.co.uk or report it in accordance with our Whistleblowing Policy as soon as possible. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with the Manager marcus@orielstudios.co.uk

 

2.2.4 We are 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 our own business or in any of our supply chains. If you believe that you have suffered any such treatment, you should inform the Manager marcus@orielstudios.co.uk immediately.

2.3 Breaches

2.3.1 We may terminate our relationship with any of our suppliers if they breach the values set out in the Policy. However where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.

2.4 Addressing Modern Slavery and Human Trafficking
2.4.1 Our Supply Chain

The current Oriel Studios supply chain includes major national companies, regional companies and small medium enterprises together with local family businesses.

The supply chain for 2024/25 included 15 active suppliers with spend at £568,000. This spend is nearly entirely spent within the North West Area of the country.

Suppliers are expected to uphold the same values and, as part of the bidding process they are required to:

  1. Confirm that they have their own Modern Slavery statement (if they meet the statutory thresholds)
  2.  Acceptance of Inserting clauses into new supplier contracts that the supplier will take its own steps to eradicate slavery and that prohibit the use of forced, compulsory or trafficked labour
2.4.2 Our Employees

When we are carrying out recruitment we ensure that we ask candidates to bring with them to interview proof of their eligibility to work in the UK. Ideally this would be via the candidate producing their passport. However if they either do not have a passport or it has expired then they would need to provide other evidence. To do this they would need to provide relevant documents as outlined in the Asylum and Immigration Guidance.

Oriel Studios Whistleblowing Policy is contained within the organisations Code of Conduct. This is cascaded to all new employees prior to them starting their employment as this forms part of phase one of their induction. This requires them to read the organisations policies and procedures prior to their first day. At their induction on their first day we check that they have read the policies and if not ensure they have time to do so within their first 4 weeks of employment.

All Oriel Studios staff have been made aware of the Oriel Studios Whistleblowing Policy which guides them as to how to raise a concern about, for example, modern slavery; anyone who raises a genuine concern under the Whistleblowing Policy will be protected against reprisals.

2.4.3 Our Customers

As part of the day to day operations for customer facing employees the following guidance is accessible and communicated:

How Staff and Contractors can Spot the Signs of Modern Slavery:

Abuse of individuals is not always clear cut. Someone could choose to work for less than the minimum wage, or in an unsafe condition, and not necessarily be forced or deceived.

Signs of slavery are often hidden, making it even harder to recognise victims. Some are more apparent, we must be consistently vigilant at all times.

All employees are provided with Oriel Studios Safeguarding Policy and where appropriate training provided to contractors – the policy has a clear reporting mechanism for all staff/contractors to ensure that if any concerns are noticed they will be actioned.

2.5 Communication and Awareness

2.5.1 The annual statement and the Anti-Slavery and Human Trafficking Policy will be communicated to all employees at least once per year.

 

2.5.2 Training on this Policy and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us.

 

2.5.3 Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

  1. Legislative or other Guidelines

3.1 Modern Slavery Act 2015 (incorporating Human Trafficking)

  1. Links to First Choice Home’s Strategic Plan

4.1 The policy enables the delivery of excellent services in the print and signage industry.

 
This Policy is approved by the Board:

Signed: Oriel Board of Directors

Dated: 22 August 2025