Slavery and Human Trafficking Statement
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps CJA Group Ltd. has taken during the financial year from 30 September 2018 to 1 October 2019 to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business.
During the last 12 months, CJA has continued to develop its processes and procedures to ensure that slavery and human trafficking is not taking place in its supply chains or in any part of the business.
Key Areas of Focus:
- Embedding procurement strategy processes in supplier selection and contracting process
- Training employees directly involved in engaging suppliers on supplier sourcing
- Reviewing risk assessments conducted in the previous year
We are committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Modern Slavery Act 2015.
Our Supply Chains
Our supply chains include media agencies, online search engines, software suppliers and developers and professional service firms. We do not act as a producer, manufacturer or retailer of physical goods and have no supply chains in relation to such activities.
Our Policies on Slavery and Human Trafficking
CJA Group’s internal policies include our Anti- Slavery and Human Trafficking Policy where we confirm our zero-tolerance approach to modern slavery and which reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We also have an Anti-Slavery and Human Trafficking Policy for Suppliers which, as well as setting out our requirements, also includes links to government guidance and factsheets.
These two policies are supported by our Whistleblowing Framework, which encourages and provides clear guidance on raising concerns in confidence relating to any wrongdoings which extends to slavery and human trafficking. All reports will be fully investigated, and appropriate remedial actions taken.
Assessment of Modern Slavery Risk within our Supply Chain
In the past year we have continued our focus on Modern Slavery, reviewing risk assessments to determine where the risk of modern slavery and human trafficking lies both within the Group and in its supply chains.
Suppliers have been assessed in terms of the nature of services they supply to the Group and the geographical risk. These assessments cover the entire scope of our business, encompassing media agencies, online SEM, and other professional service providers. Geographically, most suppliers are based in the UK (or we contract with and make payment to the UK office) with the exception of some SEM and niche job boards. We are aware from due diligence that some job boards, whilst having a UK office base with whom we have a contract, are part of global organisations and utilise the services of individuals based in countries with emerging economies.
Due Diligence Processes for Slavery and Human Trafficking
We understand that our biggest exposure to Modern Slavery remains with organisations, whilst having a UK office base, who utilise the services of individuals based in countries with emerging economies. Existing suppliers have been made aware of our zero tolerance of modern slavery and have been asked to attest their compliance with the Modern Slavery Act 2015.
Employees are required to complete refresher training covering our Code of Conduct and Human Trafficking Policy on an annual basis. Training is provided to new employees as part of their induction.
Assessment of effectiveness in preventing modern slavery
In order to assess the effectiveness of the measures taken by CJA Group Ltd. we are, or will be reviewing:
- Investigations undertaken into reports of modern slavery (including any concerns raised under our Whistleblowing Framework) and remedial actions taken in response; and
- Staff training levels.