Anti-Slavery and Anti-Trafficking Transparency Statement
Modern slavery encompasses slavery, forced and compulsory labour, and human trafficking whereby individuals are deprived of their freedom and are exploited for commercial or personal gain as enacted in the Modern Slavery Act 2015 (‘the Act’).
While Curation is not required under the Act to publish a transparency statement, it has voluntarily chosen to do so as is committed to a zero tolerance approach to modern slavery and to acting with integrity in all its dealings, relationships, and supply chains. It expects the same high standards from all its staff, suppliers, contractors, and those with whom it does business. Curation’s position on modern slavery applies to all employees, workers, consultants, and other persons doing business with Curation including all its wholly owned companies, contractors, and suppliers.
Curation acknowledges the risk that a supply chain may involve the use of a hidden or unknown subcontractor reliant on forced labour. Although Curation considers the risk of modern slavery to be low due to the nature of its relatively small supply chains, it takes its responsibilities to combat modern slavery seriously as demonstrated by its promotion and adoption of the following measures:
- The prevention, detection, and reporting of modern slavery in any part of its business or supply chains is the responsibility of all those working for Curation or under its control.
- Appropriate due diligence processes must be carried out in relation to modern slavery which may include considering human rights in a sector or country, the type of sector in which a service provider operates, the countries from which services are provided, the nature of relationships with suppliers, and the complexity of supply chain(s).
- All supply chain lines need to be continually risk assessed and managed in relation to modern slavery and any high-risk suppliers audited.
- Curation encourages anyone to raise any concerns about modern slavery and will support anyone who acts in good faith. Anyone can raise a concern by contacting a member of the Curation management team.
- Wherever possible, Curation will obtain warranties from suppliers that they are free of modern slavery (which can be passed on to sub-contractors). These warranty clauses are contained in our standard procurement contracts and purchase order terms and conditions.
- Curation also has an equal opportunities policy and is committed to upholding human rights.
- Curation will continue to develop its commitment to combat modern slavery and will provide staff training where appropriate.
- Any breaches of Curation’s position on modern slavery may result in Curation taking disciplinary action against individual(s) and/or terminating its relationship with any organisation or supplier.
The Chief Operating Officer has the primary and day-to-day responsibility for implementing Curation’s position on modern slavery, and for monitoring its use and effectiveness and dealing with any queries on its interpretation. Management at all levels are responsible for ensuring those reporting to them are made aware of and understand Curation’s position and if necessary are given adequate training on it.
Chief Operating Officer
Date: 10 December 2021