Modern Slavery Policy
Anti-Slavery and Human Trafficking Statement
Organisational structure and supply chains
thebigword Group of Companies includes Link Up Mitaka Limited, thebigword Interpreting Services Limited, thebigword International Limited, TBW Global Limited, Gould Tech Solutions Limited, thebigword Overseas Interpreting Limited, thebigword Inc, thebigword Global Communications LLC, thebigword Asia Limited,, thebigword (Beijing) Technology Co. Limited, Mitaka thebigword KK, thebigword India Private Company Limited, thebigword Deutschland GmbH.
thebigword is run as an independent company. It is a global technology-enabled language solutions provider, delivering translation (written word) and interpreting (spoken word) services to over 2500 public and private sector clients. thebigword employs over 500 people across 10 countries, working with more than 12,000 linguists worldwide. thebigword supply chain primarily comprises the linguists, along with other key service providers.
We use a wide variety of local, national and international suppliers to source language services and goods for the operation of our business. In particular we work with individual linguists and agencies. We believe that our biggest exposure to modern slavery lies in our overseas operations: Especially in Asia including but not limited to: India and China. As such, our activities relating to assessing and managing our modern slavery risks focus on our key suppliers in these geographic regions. We recognise that the nature of our supply chain can make checking for illegal activity challenging. However as explained below, there are a number of checks and safeguards we put in place to reduce the risk of modern slavery and human trafficking occurring in our supply chain.
Our policy on modern slavery and human trafficking
We have an absolute zero tolerance policy to modern slavery. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our 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 understand that modern slavery encompasses:
- Forced work, through mental or physical threat;
- Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
- Being dehumanised, treated as a commodity or being bought or sold as property; and/or
- Being physically constrained or to have restriction placed on freedom of movement.
- We acknowledge our responsibilities under the Modern Slavery Act 2015 and we are committed to preventing slavery and human trafficking within our businesses and our supply chains. We understand that this requires an ongoing review of our internal practices and continual due diligence of our supply chains.
- As part of our zero tolerance policy, we will not enter into business, and will discontinue any current business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude or forced or compulsory labour.
- We will strive to ensure that no labour provided to us in the provision of our services is obtained by means of slavery or human trafficking. We will strictly adhere to the standards required of us in relation to our responsibilities under relevant employment legislation.
Our due diligence processes
To ensure that we adhere to this policy , we will introduce the following processes:
- Conducting risk assessments to identify which parts of our businesses and supply chains are most at risk from modern slavery;
- Engaging with all our major suppliers/subcontractors/agencies to convey the contents of this policy to them, and asking them to confirm they have read and understood our policy and will adhere to it;
- Surveying our suppliers to establish what steps, measures and practices they have implemented to prevent modern slavery occurring in their organisations;
- Introducing contractual provisions into our supply contracts where appropriate to confirm that our suppliers adhere to and accept our policy; and
- Discontinuing business with any first-tier supplier found to have been involved in modern slavery.
To facilitate these processes, we maintain an accurate supplier list including key contact details. We also encourage the use of our whistleblowing policy to report any concerns regarding modern slavery and we will investigate any complaints thoroughly.
Our effectiveness in combating slavery and human trafficking
As our attitude to modern slavery is zero tolerance, we have not adopted any key performance indicators as any instance of modern slavery or human trafficking in our supply chain would be an unacceptable breach of our policy. However, we will monitor our internal compliance with this policy by recording:
- which of our major suppliers/subcontractors/agencies have read and agreed to adhere to our policy;
- wWhich of our major suppliers/subcontractors/agencies have implemented their own policies and procedures with prohibitions against modern slavery;
- which of our major suppliers/subcontractors/agencies place obligations on their own employees to comply with their modern slavery policies;
Where our suppliers do not yet have modern slavery policies and procedures in place, where appropriate we will ask for confirmation as to the likely timescale for their introduction.
Responsibility for our policy
Our Chief Executive Officer is responsible for compliance with this policy, and is the person to whom all queries or concerns regarding modern slavery should be addressed. The Compliance Team will undertake an annual review of our obligations towards eradicating modern slavery within our organisation and supply chains.
All of our employees have an obligation to familiarise themselves with our policy to help in the identification and prevention of modern slavery. This policy will be publicised internally to raise awareness. New employees will receive training on this policy as part of their induction process. In addition, all of our employees responsible for compliance or procurement will be trained on the requirements of this policy.
Review and further steps
We recognise that our commitment to a zero-tolerance approach to modern slavery is a continual journey which requires us to review and where necessary, modify our processes, on a regular basis. As such, we have reviewed the effectiveness of the steps we have taken throughout the previous financial year to ensure that there is no slavery or human trafficking taking place in any part of our business or supply chains. Following this review, we intend to take the following further steps to ensure that we continue to combat slavery and human trafficking:
We are committed to continually improving our approach to training, and as such, we will review our current training process in order to ensure that it remains comprehensive and effective.
This statement relates to the 2020 financial year and is approved by the Board.