Purpose and scope
This policy sets out Giraffe Hosting Limited’s approach to preventing modern slavery and human trafficking in its Giraffe Digital business and related business relationships. It applies to directors, employees and people authorised to act on our behalf.
Our standards are informed by the Modern Slavery Act 2015 and applicable employment and human rights law. Modern slavery can involve forced labour, servitude, debt bondage, exploitation and human trafficking.
Working standards we expect
People working for us or providing services on our behalf must be treated fairly and lawfully. The following expectations should guide engagement and supplier decisions:
- Work must be freely chosen, with freedom to leave subject to lawful and reasonable notice requirements.
- Violence, threats, coercion and restrictions on lawful movement are unacceptable.
- Identity documents must not be retained to control a worker.
- Workers must not be charged recruitment fees that place them in debt or dependency.
- Pay, working time, employment conditions and the use of young workers must meet applicable law.
- Workers must have a way to raise concerns without retaliation.
Our services and supply chain
Giraffe Digital provides website design and digital marketing services, with hosting, domains and email available through Giraffe Hosting. Relevant business relationships include technology, software, infrastructure and professional service providers, and specialist contractors where used.
Supplier consideration should extend beyond the immediate service. Subcontracting, equipment manufacture and other indirect services can introduce labour risks that need proportionate attention.
Our Anti-Bribery & Corruption Policy supports honest decisions about suppliers, contracts and payments.
Supplier checks and decisions
When selecting or reviewing a supplier or contractor, management should consider the nature of the work, where and how it is carried out, the use of subcontractors and any credible concerns about working conditions.
Checks should be proportionate to the risk. They may include confirming the business’s identity, requesting relevant policies or information about recruitment and subcontracting, and clarifying who is responsible for people carrying out the work.
A lack of information or an unusually low price should prompt questions where it may indicate exploitation. Concerns, decisions and any agreed corrective action should be recorded. Evidence of abuse must be escalated rather than treated solely as a purchasing issue.
Report exploitation or a concern
For a concern connected with our business, contact Michael Swan at michael@giraffedigital.co.uk or 0333 090 9138. If it involves your usual contact, write to the management of Giraffe Hosting Limited, 5th Floor, 167-169 Great Portland Street, London, W1W 5PF.
In an emergency or if someone is in immediate danger, call 999. Suspected modern slavery can also be reported to the police on 101 or the Modern Slavery & Exploitation Helpline on 08000 121 700. The National Crime Agency’s reporting guidance explains these options.
You do not need to prove exploitation before raising a concern. Do not confront a suspected exploiter or take action that could endanger you or another person.
Response, responsibility and review
Management must consider reports promptly, keep information appropriately restricted and decide what action or external referral is needed. Protecting people and preserving their safety should guide the response.
Where a supplier concern is identified, the response should consider the people affected, the seriousness of the risk and suitable corrective action. This may include requiring improvements, suspending work or ending a relationship where appropriate.
No one should suffer retaliation for raising an honest concern. Management is responsible for communicating this policy to people acting on our behalf and reviewing it at least annually, or sooner where circumstances require. Read About Giraffe Digital for the business background.