Modern Slavery Policy

Introduction

This statement sets out Broadsword’s actions to understand all potential modern slavery risks related to its business, and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. 

As part of the events industry, the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

Broadsword is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Broadsword:

  • A business operating within the events industry
  • Operating out of South East England and with a subsidiary in Hong Kong and New York
  • With a team of c23 people

Countries of operation and supply

The organisation currently operates in the following countries:

Austria
Australia
Belgium
China
Denmark
Finland
France
Germany
Hong Kong
Ireland
Japan
Kenya
Mexico
Netherlands
Nigeria
Norway
Portugal
Singapore
Spain
Sweden
UK
USA

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • We review our supply chain activities/​services
  • We review and monitor the products that we use in our business 
  • We keep up to date with high risk practices 

High-risk activities

We have assessed and do not consider that we operate in areas that present high risks.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: Anna Green
  • Risk assessments: Anna Green
  • Investigations/​due diligence: Anna Green
  • Training: Anna Green 

Relevant policies

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. 
  • Employee code of conduct: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
  • Supplier/​Procurement code of conduct: We ask our suppliers to confirm that they comply with our principles contained within this policy. 
  • Recruitment/​Agency workers: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. 

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking
  • Evaluating the modern slavery and human trafficking risks of each new supplier 
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
  • Taking steps to improve substandard suppliers’ practices, including providing advice and guidance to suppliers 
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our principles, including the termination of the business relationship

Performance indicators

The organisation has reviewed its key performance indicators (KPIs). As a result, the organisation is:

  • Implementing training for all new staff, with refresher training for all staff every two years 
  • Reviewing its existing supply chains whereby the organisation evaluates all existing suppliers 
  • Asking suppliers to confirm they comply with our principles 

Training and Communication

The organisation requires all employees to be aware of this policy and communicate any identified risk areas to the Board of Directors.