Modern Slavery Statement 2025/26
OUR COMMITMENT
Alethia Media Ltd is committed to minimising the risk of all forms of forced labour and human trafficking within our business and supply chain. Alethia Media Ltd forbids any form of slavery, human trafficking, forced labour and child labour, and we are committed to complying with applicable laws prohibiting such exploitation.
Alethia Media Ltd is making this statement — as required by section 54 of the UK Modern Slavery Act 2015, to ensure that modern slavery and human trafficking are not taking place in our supply chain or in any part of our business. Alethia Media Ltd policies regarding code of conduct and compliance apply to all employees and entities of Alethia Media Ltd.
ABOUT
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
Alethia Media Ltd has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships, in and implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee’s contract of employment and we may amend it at any time.
POLICIES AND PROCEDURES
The Company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
The Company has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Company Director.
Code of Conduct
Alethia Media Ltd employees are required to follow the Alethia Media Ltd Code of Conduct and report any modern slavery concerns to management. All employees are required to complete Code of Conduct training annually. Alethia Media Ltd intends for the Code of Conduct to apply equally to everyone working at, with or on behalf of User Central Ltd. This includes Alethia Media Ltd directors, officers, executives, employees, business partners and suppliers, agents and other company representatives. Anyone who violates the Code of Conduct, the law or our policies may be subject to disciplinary action, up to and including termination, in accordance with applicable laws.
Responsible Supply Chain Principles
The Alethia Media Ltd Responsible Supply Chain Principles drive our commitment to fostering sustainable business practices. We are serious about our environmental, social and financial responsibilities, and we strive to develop good relationships with suppliers who take them seriously, too. The Alethia Media Ltd Responsible Supply Chain Principles cover five main categories:
- Respecting the basic human rights of our people
- Enforcing labour standards and prohibiting child labour
- Prohibiting corruption and bribery
- Protecting the environment
- Fostering equality, diversity and inclusion
Our suppliers are required to adhere to the Alethia Media Ltd Responsible Supply Chain Principles. These principles speak to our customer commitments and relationships, which are built on trust and personal responsibility. They establish the standards required for conducting business with Alethia Media Ltd.
STRUCTURE, OPERATIONS AND SUPPLY CHAINS
Alethia Media Ltd provide world-class Content services. As a company, we work collaboratively with our clients and wider supply chain to secure the sustainable success of our customers by providing innovative solutions. We provide services in the areas of modern workplace, research, service design, functional architecture and usability testing. Alethia Media Ltd activities and industries are largely considered low risk for modern slavery. Alethia Media Ltd does not manufacture any hardware, and our core activities often require specialist skills. Our workforce is highly skilled, and English is the common language across the business. Our core activities and the industries in which Alethia Media Ltd operates keep our risk profile low for modern slavery and labour violations.
SUPPLY CHAIN MANAGEMENT OF MODERN SLAVERY CONCERNS
In all of our procurement activities, Alethia Media Ltd takes into careful consideration a set of economic, process-driven and technical criteria as well as essential social, environmental and ethical responsibilities such as human rights, labour conditions, anti-corruption concerns and environmental protection. We have supplier screening questions that we require all prospective suppliers to answer.
Our efforts cover all levels of our engagement with suppliers. We have incorporated specific questions on modern slavery and human trafficking into our initial screening survey for suppliers, so our policies are at the foundation of every interaction thereafter.
We are incorporating our modern slavery prevention efforts in our contracts with suppliers. Our suppliers are required to adhere to the Alethia Media Ltd Responsible Supply Chain Principles. These principles speak to our customer commitments and relationships, which are built on trust and personal responsibility. They establish the standards for conducting business with Alethia Media Ltd. We routinely assess performance of our key suppliers and evaluate compliance with our principles.
As our processes and policies include more stringent requirements for new and renewing contracts, we feel assured that the risk of modern slavery in the Alethia Media Ltd supply chain is low and likely to diminish.
We will continue to monitor and remain alert to any new risks that may emerge.
Due diligence
Alethia Media Ltd takes a risk-based approach to managing modern slavery and human trafficking in our supply chain. We make our commitments public via our website, we require employees to abide by several policies, and we are in the process of requiring all suppliers to have these commitments explicitly stated in contracts with Alethia Media Ltd.
EFFECTIVENESS AND PERFORMANCE INDICATORS
Our business operations and activities are considered low risk for modern slavery, and we are committed to minimising the risk of all forms of forced labour and human trafficking within our business and supply chain. We will increase our monitoring of our effectiveness to include the following key performance indicators concerning modern slavery issues:
- Percentage of staff completing Code of Conduct training
- Number of reports across all channels concerning modern slavery
- Percentage of high-risk suppliers
- Number of suppliers terminated for modern slavery infractions
With our requirement to report labour issues applicable to all employees, we are confident that our people are aware of and would report any possible incidents.
TRAINING
Alethia Media Ltd requires all employees to complete Code of Conduct training annually. Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
AUTHORISATION AND AVAILABILITY
This Modern Slavery Statement was approved by the Alethia Media Ltd executive leadership team on September 1st, 2025, and was signed by Kelly Oliver, Director, on September 2nd, 2025. This statement will be posted on our Alethia Media Ltd website and submitted to the relevant authorities.
Kelly Oliver
Company Director 02.09.25
