Policy key definitions
• “I”, “our”, “us”, or “we” refer to PHC Digital Ltd, 7 The Close, Norwich, Norfolk NR1 4DJ, UK.
• “Modern Slavery” refers to slavery, servitude, forced or compulsory labour and human trafficking as defined under the UK Modern Slavery Act 2015.
• “Supply Chain” refers to all suppliers, contractors, subcontractors, labour providers, consultants or other third parties providing goods or services to PHC Digital Ltd.
Overview
PHC Digital Ltd is committed to preventing modern slavery and human trafficking in all its business activities and in its supply chains. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings. This Statement applies to all staff (including temporary and contract workers), directors, officers, and anyone working on behalf of PHC Digital Ltd.
Our commitment
We commit to:
- Comply with all applicable laws relating to modern slavery and human trafficking.
- Ensure transparency in our own operations and in our approach to tackling modern slavery throughout our Supply Chain.
- Promote good practice and ethical conduct among all staff, contractors, suppliers and partners.
- Encourage reporting and provide mechanisms for concerns to be raised in confidence without fear of retaliation.
Responsibility and governance
The Managing Director, Pete Henshall, has overall responsibility for compliance with this Policy and for implementing and monitoring its effectiveness. Operational responsibility, including reviews of supply chain practices and due diligence, rests with the senior leadership team.
Risk assessment and due diligence
We will:
- Assess the risk of modern slavery occurring in our business and supply chains.
- Conduct due diligence on all new suppliers where appropriate and proportionate to the risk.
- Require, where relevant, commitments from suppliers to meet agreed standards on labour practices and human rights.
- Review existing relationships where risk indicators are identified and work collaboratively with suppliers to remediate and improve practices.
Staff awareness and training
We provide training and communications to staff so they understand:
- What modern slavery is.
- How it may arise in business operations or supply chains.
- How to identify and report concerns.
We reinforce that any suspected breach of this Policy is to be reported immediately via internal channels.
Reporting concerns
Staff, clients, suppliers or third parties who have concerns about potential modern slavery or human trafficking may raise those concerns in confidence by contacting the Managing Director at:
Email: contact@phc-digital.com
Tel: +44 01953 529027
We will review all reports and take appropriate action, including referral to appropriate enforcement agencies where required.
Review and continuous improvement
This Policy will be reviewed at least annually and updated as necessary to reflect changes in law, regulation, or business operations. The review includes assessment of risks, due diligence practices and training effectiveness.