Modern Slavery Policy

Introduction
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.

Creature Media Limited  has a zero tolerance approach to modern slavery of any kind and has taken steps to ensure it is not present in its internal operations or its supply chain. In addition as an accredited B Corp company we are committed to acting ethically and with integrity in all our business dealings and relationships. We are also committed 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.

Creature Media Limited. is  committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting process we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

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, interns, agents, contractors, external consultants, third-party representatives and business partners.

Our organisational structure and supply chains
Owing to the nature of our business, our supply chains consist of goods and services primarily sourced from low risk countries for the purposes of modern slavery and human trafficking.

Our policies and approach in relation to modern slavery and human trafficking
Creature Media Limited upholds the highest standards of conduct in the delivery of our services and products and adheres to well defined ethical values and practices. The key policies and procedures that relate to mitigating risks of modern slavery and human trafficking in our business and supply chain include:

• Our Mission & Values 
• Supplier Code of Conduct & Ethics
• Employee Code of Conduct
• Anti-Slavery & Human Trafficking Policy
• Environmentally Preferable Purchasing Policy
• Internship Policy
• Induction Procedure for New Starters
• Whistleblowing Policy

Due diligence procedure

Creature Media Limited carry out due diligence across our supply chain by asking existing suppliers to complete an annual survey. Potential new suppliers are asked to complete the survey before entering a business relationship or contract for services. Our due diligence procedure considers the fact that we operate in environments where there is low risk of modern slavery and human trafficking. It also assists us to gather information about our supply chain and other environmental best practices. As part of our new and existing supplier survey for modern slavery and human trafficking due dilligence we ask the following questions: 

• Where is the supplier located and where are any of its subcontractors located?
• Does the supplier  verify that it meets or exceeds living wages or fair wages for employees as identified by a third party? (Note that living wages are different from minimum wages.)
• Is the supplier subject to regular quality assurance reviews or audits by any third parties or any of your other client/customer organisations?
• Does the supplier  employ workers under the age of 15? (or other minimum work age covered by the International Labour Organisation Convention No. 138)
• Does the supplier  employ workers who are currently prisoners/incarcerated?
• Does the supplier operate or source from conflict areas?
• Has the supplier  had any material fines or sanctions in the last five years regarding Labour issues? (internal and supply chain) 

Risk assessment and mitigation

Creature Media Limited assesses risk in relation to modern slavery and other risks at departmental level. This is an on-going and standard practice. 

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

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify the Managing Director as soon as possible [email protected].

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, please raise it with the Managing Director [email protected].

We aim 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.

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. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you are a Creature Media Limited employee and believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

Responsibility for the policy
The company owner and shareholders have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. We will review this policy annually and make such changes as we deem necessary from time to time.

The Managing Director 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.

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. 

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.

Communication & awareness of this policy
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, and updates will be provided using established methods of communication between the business and you.

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

Our Whistleblowing policy enables our staff to report any wrongdoing which extends to human rights violations, including modern slavery. All employees have access to this process where concerns regarding unacceptable working practices can be reported. Reports may be made anonymously. All reports are investigated and appropriate action taken. We are committed to ensuring no-one suffers any detrimental treatment as a result of reporting in good faith their suspicion that an actual or potential modern slavery offence has taken place, or may take place in the future.

Last updated May 2025