Customer Media, LLC (TheCustomer) and its subsidiaries and brands (including Groundswell) are committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers.
Nature of the organization
In order to facilitate the services that we provide, we work with a range of suppliers these include marketing, media, research, publishing and consulting services. We are committed to ensuring there is no modern slavery or human trafficking in our supply chain or in any part of our business. Our policies as stated below reflect our commitment to acting ethically and with integrity in all our business relationships and our effort in implementing and enforcing effective systems and controls to ensure that slavery and human trafficking is not taking place within our lines of business.
Due diligence
As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our business lines, we have adopted the following due diligence procedures, new suppliers are subject to due diligence checks. If issues are identified during the due diligence process, appropriate measures are taken.
Our procedures are designed to:
- establish and assess areas of potential risk in our business and supply chains
- monitor potential risk areas in our business and supply chains
- reduce the risk of slavery and human trafficking occurring in our business and supply chains
- provide adequate protection for whistleblowers
Risk and compliance
TheCustomer supplies services to a wide variety of private sector organizations and as such is occasionally subjected to risk assessments and management audits that by their nature require TheCustomer to evaluate its exposure to the risk of modern slavery occurring in its supply chain. Be that as it may, we do not consider that we operate in high-risk sectors or locations because we do not have a large or complicated supply chain and our suppliers are typically valued well-established service providers such as creatives, developers, research companies, lawyers, and other consultants.
If we find evidence of a failure to comply with our policies, we will immediately seek to terminate our relationship with the relevant supplier.
Training
We invest in educating our staff to recognize the risks of modern slavery and human trafficking in our business and supply chains. Through our training programs, employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from our business and supply chains.
Further actions
We intend to take the following further steps to tackle slavery and human trafficking: (i) continue to seek assurances from suppliers that their and their supply chains comply with the Modern Slavery Act 2015, Human Rights Act 1998 and Modern Slavery Act 2018; and (ii) undertake an assessment and review of our policies periodically.