Modern Slavery and Human Trafficking Policy

Effective Date: 1 January 2025
Review Date: 1 January 2026

1. Introduction

Vireo Communications (“the Company”) is committed to preventing any form of modern slavery, human trafficking, or forced labour within our operations and supply chain. We believe it is our ethical duty to ensure we do not knowingly support or work with businesses that engage in any form of slavery or human trafficking.

This statement is made in accordance with the UK Modern Slavery Act 2015. While our annual turnover is below the threshold of £36 million and we are therefore not legally required to publish a statement, we choose to make this policy publicly available as a matter of good practice and transparency.

2. About Vireo Communications

  • Business Structure: We are a communications practice based in the UK, currently employing two company directors.

  • Services: We provide a range of strategic communications and PR services.

  • Geographical Reach: We partner with agencies in various regions, including China, the USA, Germany and Qatar, to support client projects.

3. Our Supply Chain

Our supply chain primarily involves:

  • Professional Services: Freelance consultants, partner agencies, and IT support.

  • International Partners: Agencies located in markets including China, the USA, Germany and Qatar that assist with client work.

Because of these international partnerships, we recognize there could be a heightened risk of labour exploitation or unethical labour practices in some regions of operation. As a result, we remain vigilant about monitoring any potential risks in these relationships.

4. Our Commitment and Zero-Tolerance Approach

  1. Zero Tolerance
    We have a zero-tolerance approach to modern slavery and human trafficking. We do not and will not knowingly engage with any supplier, partner, or business that fails to uphold these standards. If a partner or supplier is found to be engaged in modern slavery, we will take immediate steps to address or terminate our relationship with them.

  2. Legal and Ethical Compliance
    Although our annual turnover is below the legal threshold, we are committed to upholding the spirit of the Modern Slavery Act 2015. This commitment applies to all aspects of our business, from hiring practices to supplier relationships.

  3. Continuous Improvement
    We aim to continually improve our processes and awareness. Should any issues be identified, we will revise our approach, policies, and contractual agreements with suppliers to mitigate the risk of modern slavery or human trafficking in our supply chain.

5. Policies and Procedures

  1. Due Diligence

    • We will conduct proportional due diligence when onboarding new suppliers, especially those operating in higher-risk regions.

    • Ongoing reviews of existing supplier relationships will help us identify any emerging concerns.

  2. Awareness and Training

    • While we are a small team, all individuals involved in supplier selection and project management will be informed about modern slavery risks and the steps to report suspicious activity.

    • We encourage open communication so that any concerns can be raised confidentially without fear of retaliation.

  3. Reporting Concerns

    • Any employee, contractor, or supplier who suspects modern slavery or unethical labour practices must report their concerns immediately to the Company Directors.

    • We will investigate all reported concerns fairly and confidentially, in accordance with our whistleblowing and grievance procedures.

6. Responsibility for this Policy

  • Company Directors:

    • Setting the overall tone and ensuring modern slavery considerations are integrated into strategic and operational decisions.

    • Reviewing and approving this policy.

  • Contractors:

    • Adhering to this policy and reporting any signs of potential slavery or trafficking in day-to-day activities.

    • Participating in training or awareness sessions, as required.

7. Monitoring & Review

We will review this policy annually or sooner if required by any significant change in operations or regulations. This ensures it remains effective, up-to-date, and aligned with both legal requirements and best practices.

Approved By:
Alexandros Michaelides, Company Director
Date: 1 January 2025

Contact

If you have any questions or concerns regarding this policy, please contact:
Vireo Communications
Email: hello@vireocomms.com

Published on: 1 January 2025