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This statement covers 1 January 2024 to 31 December 2026 and has been approved by the board of Culture Gem Ltd at the board meeting on 1 January 2024.

Modern Slavery

Our business and supply chains 

Culture Gem Ltd is a UK-based integrated business solutions company, providing eLearning, coaching, training and graphic design focused on helping British companies meet their stated objectives on time and within budget.

Risk assessment 

In the past year, we conducted a risk assessment of our supply chain by taking into account:  

  • The risk profile of individual countries based on the Global Slavery Index 

  • The business services rendered by the suppliers 

  • The presence of vulnerable demographic groups 

  • A news analysis and the insights of labour and human rights groups 


This assessment will determine our response and the risk controls that we implement. 

Anti-slavery policy

Culture Gem Ltd operates the following policies for identifying and preventing slavery and human trafficking in our operations: 

  • Whistleblowing Policy - we encourage all employees, customers, and suppliers to report any suspicion of slavery or human trafficking without fear of retaliation. Whistleblowers can contact Protect-Advice - the site  provides clear instructions on how to raise concerns.

  • Code of Conduct - our code encourages employees to do the right thing by clearly stating what is expected of them when representing the business. We maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing our supply chain. 

  • Purchasing Code - we have updated our Purchasing Code and supplier contracts to make explicit reference to slavery and human trafficking. 

Supplier due diligence 

Culture Gem Ltd conducts due diligence on all new suppliers during on-boarding and on existing suppliers at regular intervals. Culture Gem:  

  • Assesses risk in the provision of services 

  • Audits suppliers, their health and safety standards, labour relations, and employee contracts 

  • Requires improvements to substandard employment practices 

  • Sanctions suppliers who fail to improve their performance in line with requirements 


We require all suppliers to attest that: 

  • They do not use any form of forced, compulsory or slave labour 

  • Their employees work voluntarily and are entitled to leave 

  • They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment 

  • They don't require employees to post a deposit/bond and don't withhold their salaries for any reason

  • They don't require employees to surrender their passports or work permits as a condition of employment 


Culture Gem Ltd has raised staff awareness of modern slavery issues by highlighting (posters, email): 

  • Our commitment to the fight against modern slavery 

  • Red flags for potential cases of slavery or human trafficking 

  • How employees should report suspicions of modern slavery


In addition to the awareness programme, Culture Gem Ltd has rolled out a fresh e-learning course to all employees and supplier contacts, which covers: 

  • The forms of modern slavery where people are held and exploited 

  • The size of the problem and the risk to our organisation 

  • How to identify signs of slavery and human trafficking, including unrealistically low prices 

  • How to respond if they suspect slavery or human trafficking 

  • How suppliers can escalate potential slavery or human trafficking issues to the relevant people within their own organisation 

  • External help available to victims of slavery 

  • Terms and guidance provided to suppliers in relation to slavery policies and controls 

  • Steps Culture Gem Ltd will take if a supplier fails to implement anti-slavery policies or controls 

  • An attestation from employees that they will abide by Culture Gem’s anti-slavery policy 

Measuring performance 

Culture Gem Ltd has defined a set of key performance indicators and controls to combat modern slavery and human trafficking in our organisation and supply chain. These include: 

  • How many employees have completed mandatory training? 

  • How many suppliers have filled out our ethics questionnaire? 

  • How many suppliers have rolled out an awareness and training programme that is equivalent to ours? 

  • How many reports have been made by our employees that indicate their awareness of and sensitivity to ethical issues? 

  • What are the findings of our cross-functional Human Rights team, which reviews how we are addressing modern slavery and human trafficking? 

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