Modern Slavery Statement

Introduction

This statement sets out Sleek’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 supply chains. As part of the live experience marketing and hospitality sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Sleek, a live experience marketing agency, delivering live events for clients spanning various professional sectors.

  • We enlist the support of local service providers and venues to help us deliver events domestically and internationally.

  • We procure the services of merchandise and printing suppliers to promote our clients’ brands. 

The following passages outline our process to assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:

  • We consult the OC (Organized Crime) Index before working on a project based overseas to assess the potential presence of modern slavery practices in the host country https://ocindex.net/

  • The OC Index will also outline the sectors/activities most at risk for slavery or human trafficking in the host country and an opportunity to recognise if an event could be at risk.

High-Risk Activities

The following event-related activities are considered to be at high risk of slavery or human trafficking according to the United Nations:

  • Fashion and apparel (which is at risk of spanning into event merchandise supply chains)

  • Hospitality (particularly cleaning, maintenance and security staff in venues/hotels)

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

  • Policies: Our People Experience team is responsible for putting in place, reviewing, and updating this policy. It was developed by consulting best practice from human resources legal advice, the OC Index, and United Nations resources.

  • Investigations/due diligence: Our Operations Team and Relationships Director will regularly consult The OC Index. We will be building out further assessment criteria for our suppliers before we engage them.

  • Training: We periodically deliver health and safety training which includes how to recognise and assess the risk of human trafficking.

Relevant policies 

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: We encourage all our colleagues, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Colleagues, customers, or others who have concerns can raise these in confidence with our People Experience team.

  • Company values and behaviours: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our business and projects supply chain.

  • Supplier code of conduct: We have a wider supplier code of conduct which includes further details. Within this, it outlines how we are committed to ensuring that our suppliers adhere to the highest standards of ethics. Suppliers will be required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Any identified serious violations of our supplier code of conduct will lead to the termination of the business relationship. We will require that all suppliers sign our code of conduct to assert compliance with our required standards as part of our working relationship and onboarding with Sleek. 

We undertake due diligence when considering taking on new suppliers, and will regularly review our existing suppliers. Our due diligence and reviews will include: 

SUPPLY CHAIN

  • 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.

  • Invoking sanctions against suppliers or terminating our business relationship if they are found to contravene our Supplier Code of Conduct.

RECRUITMENT AGENTS / GIG WORKERS

  • We use only specified, reputable recruitment partners to source labour and always verify the practices of any freelancers/consultants before engaging in a working relationship. 

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we:

  • Require our HR Professionals to report any updates to modern slavery practices from consulting reputable sources (e.g. Watershed Law, CIPD and Brightmine)

  • Will establish evaluation criteria by which we’ll review our existing supply chains and existing suppliers (criteria to be established in 2025).

Training

We require all colleagues working in event operations within our organisation to complete training on modern slavery as a module within our wider health & safety training. 

Our modern slavery training covers:

  • The use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline.

  • How to assess the risk of slavery and human trafficking in relation to various project and operational aspects, including resources and support available.

  • How to identify the signs of slavery and human trafficking.What initial steps should be taken if slavery or human trafficking is suspected.

  • How to escalate potential slavery or human trafficking issues to the relevant parties within our organisation.

  • What external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative.

  • What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies.

  • What steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.