Please Hold (UK) Limited, PH Media (USA) Inc., Please Hold Canada Inc. and Please Hold Australia Pty Limited, operating as PHMG, recognises its responsibility and 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.
This statement has been published in accordance with section 54(1) of the Modern Slavery Act (2015). It sets out the actions taken by PHMG to prevent modern slavery in our business operations and supply chains. The statement applies for the financial year ending 2019.
The supply chain that supports our business comprises a wide range of suppliers, from smaller businesses to global companies.
Our supply chain includes products and services from IT hardware and software, office design, fit-out and maintenance to recruitment agents and cleaning suppliers.
We expect our suppliers and their supply chains to adopt reasonable and practical steps to comply with the Modern Slavery Act 2015 and are undertaking an ongoing review of our existing supplier contracts / agreements to assess the risk associated with those suppliers. This includes reviewing our procurement process from sourcing to contract award, to identify how we can reduce the potential for risk of modern slavery in our supply chain.
We employ over 550 staff globally with the majority based in our offices in Manchester, UK, and Chicago, USA.
The majority of our workforce is employed on a permanent basis. All employees who join the organisation are required to provide evidence of legal right to work in the country where they will be based.
Our Employee Handbook details our processes and policies and is issued to all new starters.
The organisation undertakes due diligence when considering taking on new suppliers.
We continuously review our supply chains as part of our process to identify and mitigate risk. Given the nature of our suppliers’ business operations and the fact that none of our suppliers are based in countries considered high risk by the Global Slavery Index we consider our risk to be low.
The organisation's due diligence and reviews include [select the relevant actions from the list below]:
- 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 [this may be part of a more general human rights or labour rights assessment];
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
- creating an annual risk profile for each supplier;
- removing suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Our Board of Directors have overall responsibility for ensuring compliance with the organisation's anti-slavery initiatives.
Supplier contracts require Director approval and sign off.
This statement was approved on [date] by the organisation's [board of directors/members], who review and update it annually.
[Director's/Designated member's/Partner's] signature:
[Director's/Designated member's/Partner's] name: