Anti-Modern Slavery Policy

1. Policy Statement

[MIDiA Research Ltd] (“the Company”) is committed to preventing modern slavery, forced labour, human trafficking, child labour, and all forms of exploitation within our operations and supply chains. As a UK-based business operating globally, we recognise our responsibility under the UK Modern Slavery Act 2015 and applicable international labour standards, including those of the International Labour Organization (ILO).

We adopt a zero-tolerance approach to modern slavery and expect the same high standards from all employees, contractors, suppliers, and business partners worldwide.

2. Scope

This policy applies to:

  • All employees, workers, directors, and officers of the Company
  • All contractors, consultants, agency workers, and temporary staff
  • All suppliers, service providers, recruiters, labour brokers, and business partners
  • All jurisdictions in which the Company operates or provides services

3. Definitions

Modern slavery includes slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, child labour, and practices restricting workers’ freedom or dignity.

4. Prohibition of Forced Labour and Withholding of Documents

4.1 Policy Commitment

The Company strictly prohibits:

  • Forced, bonded, or involuntary labour
  • Retention, confiscation, destruction, or withholding of workers’ identity documents, passports, visas, work permits, or immigration papers

Retention, confiscation, destruction, or withholding of workers’ identity documents, passports, visas, work permits, or immigration papers

4.2 Process and Controls

  • Workers must retain possession and control of their own identity and immigration documents at all times.
  • No employee, manager, recruiter, supplier, or third party may request or require the surrender of original documents as a condition of employment.
  • Where copies of documents are required for lawful verification purposes, copies only will be taken with the worker’s consent.
  • Compliance checks are conducted through audits, worker interviews, and supplier assessments.

5. Recruitment Practices and Prohibition of Labour Brokers and Child Labour

5.1 Ethical Recruitment

The Company is committed to responsible recruitment practices and does not permit:

  • The use of unauthorised recruiters or labour brokers
  • Recruitment fees charged to workers at any stage of the recruitment process
  • The use of child labour in any form, consistent with ILO standards and local law

5.2 Process and Controls

  • Recruitment is conducted directly by the Company or through approved recruitment agencies that meet our ethical standards.
  • All approved recruiters must contractually agree to comply with this policy and applicable labour laws.
  • Due diligence is carried out on recruitment partners, including age verification, right-to-work checks, and audit rights.
  • Any supplier or recruiter found to be using child labour or unethical recruitment practices will be subject to immediate remediation or termination of the relationship.

6. Work Agreements and Pre-Relocation Requirements

6.1 Policy Commitment

All workers, including those hired through recruiters, must receive clear, accurate, and legally compliant work agreements.

6.2 Process and Controls

  • Workers must be provided with written employment contracts or equivalent work papers prior to commencing employment.
  • Where relocation is required, contracts must be issued before relocation occurs.
  • Agreements must include, at a minimum:
    • Job role and duties
    • Wages, benefits, and payment frequency
    • Working hours and rest periods
    • Location of work
    • Duration of employment (where applicable)
    • Termination rights and notice periods
  • Contracts must be provided in a language the worker understands.
  • Workers must be given sufficient time to review agreements and ask questions before acceptance.

7. Right to Terminate Employment Without Financial Penalty

7.1 Policy Commitment

The Company respects the freedom of workers to leave employment voluntarily.

7.2 Process and Controls

  • Workers, including migrant workers, may cancel or terminate their work contracts at any time without financial penalty.
  • Termination is subject only to reasonable notice requirements as defined by:
    • Local employment law, or
    • Applicable collective bargaining agreements
  • The Company does not permit:
    • Exit fees, penalty clauses, or repayment demands linked to recruitment or relocation
    • Retention of wages, benefits, or documents to prevent resignation
  • Any relocation or recruitment costs are borne by the Company or employer, not the worker.

8. Reporting Concerns and Whistleblowing

Workers and third parties are encouraged to report concerns related to modern slavery or unethical practices without fear of retaliation. Reports may be made confidentially through:

  • Line management
  • Human Resources
  • The Company’s whistleblowing or ethics reporting channels

All reports will be investigated promptly and appropriately.

9. Training and Awareness

  • Relevant employees, particularly those involved in recruitment, procurement, and management, receive training on modern slavery risks and prevention.
  • Suppliers and partners are made aware of this policy and expected to comply.

10. Monitoring, Compliance, and Review

  • The Company monitors compliance through audits, assessments, and periodic reviews.
  • This policy is reviewed annually and updated as necessary to reflect legal or operational changes.

11. Accountability

Responsibility for implementing and enforcing this policy sits with senior management, supported by Human Resources.