This statement sets out Novagram Limited’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities occurring during the financial year 1 April 2023 to 31 March 2024.
As part of the design and branding industry, Novagram Limited recognises that it has a responsibility to take a robust approach to slavery and human trafficking, as all businesses do.
Novagram Limited is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
This statement covers the activities of Novagram Limited:
- Novagram Limited is a design agency based in London, UK. Novagram Limited carries out the following business activities:
– Digital development
– Brand consulting
- Novagram Limited works with freelancers and contractors based in the UK and India.
- Novagram Limited also occasionally uses the services of manufacturers in the UK and the US when necessary (e.g. to produce materials that have been designed for a client).
Countries of operation and supply
Novagram Limited currently operates in the following countries:
The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
- If Novagram Limited requires the services of a supplier that operates in a high-risk industry (for example, apparel manufacturing), or the services of a supplier that operates in a high-risk country (e.g. United Arab Emirates), we will ensure that the supplier we choose has a robust anti slavery and human trafficking policy in place.
Wherever possible, we will choose suppliers that are based in the UK, or as locally as possible. We will also choose suppliers that have a small supply chain, when possible.
The following activities are considered to be at high risk of slavery or human trafficking:
- Novagram Limited considers outsourcing the production of apparel and merchandise to be a high-risk activity.
- Novagram Limited is committed to ensuring that its suppliers adhere to the highest standards of ethics. We only work with suppliers who are able to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
- We will terminate the contract of any employee, freelancer, contractor or supplier who violates this policy.
- All relevant parties working with Novagram will be made aware of this policy and must agree to adhere to it.
Responsibility for Novagram Limited’s anti-slavery initiatives is as follows:
- The responsibility for policies, risk assessments, investigations/due diligence, and training lies with Peter Dean, Novagram Limited’s Managing Director.
- These responsibilities include:
– Putting in place and reviewing policies, and the process by which they were developed.
– Carrying out human rights and modern slavery risk analysis.
– Enacting investigations and due diligence in relation to known or suspected instances of slavery and human trafficking.
– Overseeing all training relating to modern slavery and human trafficking risks.
Novagram Limited has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, Novagram Limited is:
- Requiring all staff to have completed training on modern slavery by December 31 2023;
Novagram Limited requires all staff working within the organisation to complete training on modern slavery. Novagram Limited’s modern slavery training covers:
- Our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
- How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- How to identify the signs of slavery and human trafficking;
- What initial steps should be taken if slavery or human trafficking is suspected;
- How to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
- What external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative
As well as training staff, Novagram Limited has raised awareness of modern slavery issues by circulating a series of emails to staff.
The emails explain to staff:
- The basic principles of the Modern Slavery Act 2015;
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
- What external help is available, for example through the Modern Slavery Helpline.
Contact details and statement approval
Nominated anti-slavery lead:
We are committed to reviewing our policy and good practice annually.
This policy was last reviewed on: 5 December 2023
Signed: Peter Dean
Date: 5 December 2023