Modern Slavery Policy

Introduction

1. Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. It is a real problem for millions of people around the world, including many in developed countries, who are being kept and exploited in various forms of slavery.  Every company is at risk of being involved in this crime through its own operations and its supply chain.
2. At Arke Agency Ltd (Arke), we have a zero-tolerance approach to modern slavery and are fully committed to preventing slavery and human trafficking in our operation and supply chain. We have taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out the actions that we have taken to understand all potential modern slavery risks related to our business, and to implement steps to prevent slavery and human trafficking.

Our Business and Supply Chains

1. We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the supplier’s reputation, respect for the law, modern slavery policies, compliance with health, safety and environmental standards and references.
2. We have not been made aware of any allegations of human trafficking/slavery activities against any of our suppliers, but if we were, then we would act immediately against the supplier and report it to the authorities.

Risk Assessment

1. We conduct risk assessments of our supply chain by taking into account:

• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups.

This assessment will determine our response and the risk controls that we implement.

Policies

1. Arke operates the following policies for identifying and preventing slavery and human trafficking in our operations:

• Whistleblowing policy – we encourage all employees, customers and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. 
• Code of conduct and ethics– our code encourages employees to do the right thing, by clearly stating the actions and behaviour expected of them when representing the business. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating whether that is abroad or locally and managing our supply chain.

Supplier Due Diligence

1. Arke conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. This includes:

• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements.

1. We require all suppliers to attest that:

• They do not use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work 
• They provide each employee with an employment contract that contains a reasonable notice for period for terminating their employment
• They do not require employees to post a deposit/bond and do not withhold their salaries for any reasons
• They do not require employees to surrender their passports or work permits as a condition of employment.

Training

1. Arke aims to train the relevant staff members:

• Various forms of modern slavery in which people can be held and exploited
• The size of the problem and the risk to our organisation
• How employees can identify the signs of slavery and human trafficking, including unrealistically low prices
• How employees should respond if they suspect slavery or human trafficking

Training materials: Skillcast Modern Slavery Course (Please request the portal login from the Operations Executive)

• How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation
• What external help is available for the victims of slavery
• What terms and guidance should be provided to the suppliers in relation to slavery policies and controls
• What steps Arke takes if a supplier fails to implement anti-slavery policies or controls
• An attestation from employees that they will abide by Arke’s anti-slavery policy.

Performance Measurement

1. Arke has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These includes:

• How many employees have completed mandatory training?
• How many reports have been made by our employees that indicate their awareness of and their sensitivity to ethical issues

Signed:
Steph Noble: Director and Founder

Last Reviewed: 5th January 2024