Introduction

The UK Modern Slavery Act 2015 makes it clear that modern slavery is a criminal act and a violation of fundamental human rights. It encompasses various forms, including slavery, servitude, forced and compulsory labour, and human trafficking - practices which deprive an individual's liberty so as to exploit them for personal or commercial gain.

Affinity is committed to conducting business with ethical integrity and we maintain a zero-tolerance policy towards modern slavery. 

This Modern Slavery Statement, has been prepared to make clear our commitment to ensuring that modern slavery is not present within our own operations, or in our supply chains. 

By setting this statement out in writing, we are making our intentions clear, and demonstrating how we will uphold our values and hold ourselves to account.

About Affinity

Affinity Digital (Technology) Limited is a limited company registered in England, company number 05012752. Our registered office address is Woodbine Farm Business Centre, Truro Business Park, Threemilestone, Truro, Cornwall TR3 6BW.

We are a technology company providing software development and related services to both private and public sector organisations.

Measures we are taking

Our organisational values and operational practices reflect our commitment to conducting business with ethical integrity. 

Affinity staff and colleagues

Our Diversity, Equity and Inclusion Policy describes the particular attention we pay to how we value and treat our own staff and colleagues, as well as those within the communities in which we operate. It sets out how we will:

• nurture and encourage an open and supportive culture;
• provide and encourage continuing professional development for all staff and colleagues, at all levels;
• measure staff satisfaction as an objective within our Quality Management System (ISO9001);
• pay all colleagues (staff and contractors, without exception) above the real living wage;
• promote and support the physical and mental wellbeing of all staff and colleagues;
• foster an open and supportive culture;
• maintain and promote an open-door policy for airing concerns and grievances and for whistleblowing.

Supply chain

We expect the same standards from our suppliers and the communities in which we operate, maintaining our zero-tolerance policy toward any violation. Our Supplier Policy takes into account our suppliers’ cultural alignment with our own, including their approach and commitment to modern slavery.

Assessing and managing modern slavery risks

Due to the type of services we provide and the nature and composition of our suppliers, we do not consider ourselves as operating in a high-risk sector. Nevertheless we continuously monitor potential risk areas in our business and supply chains, in accordance with our documented Risk Assessment and Treatment Procedure, and our Supplier Policy focuses specifically on minimising the risk of slavery and human trafficking occurring within our supply chains. 

If necessary, periodic audits on certain suppliers can be conducted to ensure compliance.

Measuring the effectiveness of our actions

All of Affinity’s policies, including those specifically mentioned in this Modern Slavery Statement, set out how we will:

• Ensure that they are being followed, 
• Measure how effective they are in achieving their objectives and upholding our standards, 
• Continuously improve our policies and our implementation of them,
• Hold our people to account. 

Communication and training

All employees will be made aware of this Modern Slavery Statement and of the expectation we have of them to uphold and promote the values and intentions we have set out.

This statement and the supporting policies will be:

• Referenced in the employee handbook;
• Included in induction activities or resources;
• Promoted at staff and colleague events;
• Made available to access from the staff intranet or shared drives and servers.

Staff will also be made aware of their own responsibilities in implementing the actions, including raising any issues or concerns, or seeking help if needed, in order that they can fully support it. 

The Chief Operating Officer will ensure that the actions are implemented across the business. 

Updates to this statement will be provided to all staff through line management and /or via automated system notifications when documentation is updated.

Reviewing and monitoring this policy

The Senior Leadership Team (SLT) will be responsible for regularly reviewing this Modern Slavery Statement, as well as monitoring its effectiveness. This will be achieved through:

• Integration of this statement and the supporting policies into our quality management system (QMS);
• Modern slavery focussed risk assessment and risk management;
• Gaining feedback from staff;
• Reporting and analysis of HR information contained within BambooHR, relating to representation and performance of marginalised groups; 
• Comparing our measures and successes against published information relating to our competitors and peers;
• Assessing uptake of measures that we have put in place;
• Conducting exit interviews when staff leave.

Reporting

Affinity’s performance against the measures documented within this statement will be assessed as part of our internal performance monitoring, and recorded at our regular SLT meetings (in accordance with the ISO 9001:2015 standard).

Accountability

All staff and colleagues working for Affinity are individually accountable for ensuring that they conduct themselves in a manner which upholds and reflects the values and principles set out in this statement and the supporting policies. 

The Senior Leadership Team is accountable for ensuring that the teams they manage are upholding and supporting the values and principles set out. If improvements are needed, they should set these as goals, along with appropriate training, as part of their team members’ CPD. 

The owner of this statement, with overall accountability for our adherence to it, is the Chief Operating Officer (COO).