1.1. 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. Innovate Comms is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective and proportionate systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
2.1. Innovate Comms is a UK-based marketing agency providing creative services to clients across the technology and innovation sectors. Our services include marketing strategy, brand development, content creation and event management.
3.1. Innovate Comms’s procurement activities are undertaken in the UK, and most suppliers are UK based, and all suppliers are based in the UK, EU/EEA and US. We maintain oversight of our supply chain to ensure compliance with relevant legislation and ethical standards, and we require suppliers to uphold the same high standards we set internally. We expect all suppliers to fully comply with the Modern Slavery Act 2015, including by making their own section 54 Statement where applicable.
4.1. Innovate Comms’s Anti-Slavery & Human Trafficking Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also have the following policies in place relevant to modern slavery, which we continuously review and update:
4.1.1. Innovate Comms’s procurement policies, processes and procedures require all suppliers to confirm their compliance with the Modern Slavery Act 2015. Those who declare that they do not comply will be excluded or disqualified from the procurement process.
4.1.2. Our Supplier Code of Conduct sets out clear expectations around ethical business practices.
4.1.3. Our Whistleblowing Policy protects individuals who report concerns around potential wrongdoing, including modern slavery.
5.1. Innovate Comms has in place processes and procedures to:
5.1.1. identify, assess and monitor potential risk areas in our supply chains;
5.1.2. mitigate the risk of slavery and human trafficking through contractual clauses, supplier checks and ongoing monitoring;
5.1.3. Conduct supplier vetting and periodic reviews to confirm compliance;
5.1.3. protect whistleblowers and encourage transparent reporting.
6.1. While our suppliers are based in low-risk regions (UK, EU/EEA, US), we acknowledge that certain categories of procurement—such as promotional goods or event-related materials sourced internationally—may carry higher risks.
Steps taken include:
6.1.1. prioritising suppliers with transparent ethical sourcing practices;
6.1.2. requesting evidence of suppliers’ own modern slavery statements or policies;
6.1.3. monitoring for red flags in higher-risk categories, such as labour-intensive or overseas manufacturing.
7.1. We measure our effectiveness in preventing modern slavery by monitoring and reporting against the following indicators:
7.1.1 percentage of suppliers required to provide modern slavery compliance statements (target: 100%);
7.1.2. number of suppliers subject to due diligence checks each year;
7.1.3. number of staff trained on modern slavery awareness;
7.1.4. audit findings and corrective actions completed.
8.1. To ensure awareness and vigilance across our business, we provide:
8.1.1. induction training for all new team members on ethical business conduct, including modern slavery awareness;
8.1.2. periodic refresher training on recognising risk factors and reporting concerns;
8.1.3. access to resources and guidance for procurement staff to strengthen supplier engagement and oversight.
9.1. This statement is made voluntarily in alignment with section 54(1) of the Modern Slavery Act 2015 and constitutes our company’s slavery and human trafficking statement for the financial year ending 31st March 2024. It was approved by the Innovate Comms CEO (company director) on 1st May 2024, and reviewed and updated on 1st May 2025.