Anti-Slavery & Human Trafficking Statement

Smithfield Studio Ltd (“Smithfield”, “we”, “our”, “us”) has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. Smithfield also expects the same high standards from all of its suppliers, contractors and business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will in turn hold their own suppliers to the same standards.

Modern slavery is a heinous violation of human rights that exploits vulnerable individuals. This criminal practice manifests in several ways, including:

1. Slavery: The complete ownership and control of a person
2. Servitude: Forcing someone to live and work on another’s property
3. Forced or compulsory labour: Coercing individuals to work against their will
4. Human trafficking: The recruitment, transportation, and exploitation of people

These practices represent severe infringements on personal freedom and dignity, often targeting society’s most vulnerable members. Modern slavery undermines basic human rights and demands vigilant efforts to identify, prevent, and eradicate such exploitation in all its forms.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Smithfield accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for Smithfield or on Smithfield’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the policy

The board of directors has overall responsibility for ensuring that this policy complies with Smithfield’s legal and ethical obligations.

The directors have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in Smithfield’s business or supply chains.

Managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance

The prevention, detection and reporting of modern slavery in any part of Smithfield’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for Smithfield or under Smithfield’s control.

Smithfield aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. Smithfield is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

If a breach or conflict with this policy is seen or suspected by an individual working for Smithfield or on Smithfield’s behalf, this should be reported to senior management immediately. The government’s Modern Slavery Helpline is also available on 0800 0121 700 for further information and guidance on modern slavery.

Training and communication

Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.

Smithfield’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Breach of this policy

Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct.

Smithfield may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.

Our business & structure

Smithfield Studio, a Company registered in England in 2021, our Company N⁰: 13134591

Our correspondence address is:

81-82 Castle Street
Canterbury
Kent
CT1 2QD

We currently operate in the UK and work with partners from across Europe and the United States.

Smithfield primarily provide web design, branding and web development services along with related products, services and support to our partners, who are small to medium businesses that mainly operate in the UK and Europe. You can find out more about our business activities and who we’ve partnered with in the past within our full work index https://smithfield.studio/work/ As of 15th January 2025, Smithfield Studio Ltd have 4 full and part-time direct employees.

Signed by Mike Sheppard & Adam Hunt
Directors of Smithfield Studio Ltd.