Modern Slavery Statement

Statement for the financial year

Introduction

This statement is made and published on behalf of Consumer Thoughts Limited pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. As mandated by the Modern Slavery Act 2015 (the "Act"), this statement outlines the measures Consumer Thoughts Limited has taken during the financial year to ensure that slavery and human trafficking are not occurring within our supply chains or in any part of our business operations.

Our Business, Organisational Structure, and Supply Chains

Consumer Thoughts Limited operates as an international company providing e-recruitment services to organisations across various sectors, including governmental and regulatory bodies, and social charitable organisations both globally and locally. Our business primarily operates from office and remote locations, with a supply chain that includes individuals and companies providing essential goods and services such as stationery, IT equipment, technology services, professional services, business travel, events, and catering services, as well as recruitment agencies that supply us with critical staff. The majority of our suppliers are based in the UK, and we maintain long-term relationships with them, regularly renewing contracts to reassess their services and ensure compliance.

Our Policies on Slavery and Human Trafficking

Our Anti-Slavery and Human Trafficking Policy demonstrates our commitment to ethical conduct and integrity in all business relationships, implementing effective systems to ensure that slavery and human trafficking are not occurring within our operations. Despite being generally assessed as low risk for modern slavery, we have implemented policies such as whistleblowing protection, equal opportunities, anti-bribery and corruption measures, and contract protocols.

We hold our contractors, suppliers, and business partners to the same high standards, including specific prohibitions against the use of forced, compulsory, or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We have introduced a Modern Slavery Code of Conduct for our suppliers, outlining the minimum standards we expect regarding slavery and human trafficking and requiring that they hold their own suppliers to the same standards. We have also revised our standard terms and conditions for recruitment agencies and other third parties to ensure appropriate contractual provisions are in place.

Our supplier contracts include clauses committing to combatting modern slavery and human trafficking, and we continuously review our policies and processes to ensure compliance with the law and best practices.

Risk Assessment, Due Diligence, and Actions to Prevent Modern Slavery

We recognise that the greatest risk of modern slavery lies within our supply chains. Therefore, we require all new suppliers to sign a supplier form affirming their regulation and review before onboarding. Suppliers must sign a modern slavery code of conduct setting out the standards we expect before we can establish them as one of our suppliers. This process ensures we engage with suppliers who share our values and commitment to ethical conduct and integrity.

We have a dedicated team identifying risks related to modern slavery, ensuring that our existing suppliers demonstrate compliance. We apply robust policies and procedures to centralise all supplier information and modern slavery codes of conduct. To date, we have not identified any occurrences of modern slavery within our supply chain or unresolved risks through additional due diligence or supplier engagement.

Consistent with our risk-based approach, we require employment and recruitment agencies and other third parties supplying workers to confirm their compliance with our Code of Conduct and all applicable laws and standards, including the Modern Slavery Act. We expect them to have appropriate policies and procedures to prevent child labour, modern slavery, and human trafficking within their own operations and supply chains.

We have conducted audits of our suppliers for compliance with our Code of Conduct, Anti-Slavery and Human Trafficking Policy, and Modern Slavery Code of Conduct as part of our risk assessment and due diligence processes. Our personnel are responsible for monitoring compliance and adherence to Consumer Thoughts Limited's values, implementing practices and programmes that support these values.

Employees

All our employees are fairly compensated and granted organisational benefits. At a minimum, we ensure our employees are paid above the Living Wage. Salary payments are made directly to employees and not withheld unless justified and notified in advance. Employees have the freedom to terminate their employment and are never forced to work overtime. We aim to employ both permanent and temporary staff from reputable recruitment agencies, entering binding contracts with these agencies to ensure their integrity and commitment to combating modern slavery.

Training

Our policies provide clear standards underpinning our commitment to tackling modern slavery. To embed these policies in our culture and raise awareness of the Modern Slavery Act 2015, we share this statement and provide information to employees through internal communication channels. Additionally, a copy of this statement is available on our website. In the future, we aim to provide training on modern slavery and human trafficking for customer and supplier-facing employees to improve awareness and processes for identifying, monitoring, and preventing modern slavery throughout our operations.