Local TV continues to recognise our legal and moral obligations to comply with the UK’s Modern Slavery Act and we are dedicated to running our operations in a socially responsible manner. The Act defines modern slavery as “slavery, servitude, and forced or compulsory labour” as well as “human trafficking”. We are committed to ensuring that modern slavery in any form has no place in or in connection with our organisation, and are pleased to reinforce that commitment through this statement. We believe that a structured and controlled approach to managing our workforce and supply chain is paramount in ensuring we are able to continue to be one of the leading production companies in the UK and around the world. We comply with all applicable employment legislation relating to the engagement of staff, including pay and conditions, and we invest heavily in supporting the health and wellbeing of our staff.
This statement endorses the United Nations Guiding Principles on Business and Human Rights and supports the principles contained within the International Bill of Human Rights and the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.
Business structure, operations and supply chain
Headquartered in Leeds, Local TV Media Group, Ltd. is the largest local broadcast television group in the UK and one of the UK leading diversified local media companies. Local TV has a range of engagement relationships with its workforce from office based staff and newsgathering teams through to freelancers. Local TV seeks to partner with suppliers that adopt the same strict standards that we do. We expect our suppliers to operate fair and ethical workplaces and practices, where workers are treated with dignity and respect, and the highest standards of human rights are upheld.
We also expect our suppliers to engage with us constructively and responsibly, and to demonstrate their willingness to address modern slavery-related issues in a timely manner, should such an issue arise. Local TV will refuse to partner with suppliers and other stakeholders that do not achieve or are unable to demonstrate progress towards the eradication of modern slavery within their organisations and/or supply chains.
Local TV Modern Slavery Policy
Our Modern Slavery policy specifies the actions we are taking to minimise the risk of modern slavery and human trafficking occurring in our operations and supply chains. It applies to all Local TV employees and freelancers. We also expect our suppliers to abide by this policy, as referenced in our standard conditions of contract. Our policy is that we will:
- Aim to prevent and mitigate instances of modern slavery which are linked to our business operations and supply chain
- Robustly address any instances of modern slavery which we find that our business operations have contributed towards
- Identify, understand, and promote awareness of modern slavery risks and issues pertinent to our field of operations
- Comply with the UK’s Modern Slavery Act 2015, including by fulfilling our annual compliance obligations in publishing a ‘Modern Slavery Act Transparency Statement’ for each financial year
Grievance and Reporting
Local TV encourages honest and open communication with all our stakeholders, including those working for us or for our suppliers and those impacted by our operations.
Our whistleblowing arrangements can be used for the disclosure of suspicions relating to instances of modern slavery, thereby encouraging its reporting and prevention in any part of our business and supply chain. If anyone suspects or knows of any modern slavery-related activity, we urge that individual to report it immediately either to their line manager, or anonymously via our online web portal, ‘SpeakingUp’ app or whistleblowing helpline. These services are available for use by all employees to report any instance of unethical behaviour or any suspected instances of modern slavery.
In the event that we become aware of a case of modern slavery occurring within our operations or supply chain, we commit to investigating the cause of the violation so that we can take appropriate steps to eliminate this contravention and prevent a reoccurrence. In any such case, we would prioritise the response that produces the safest outcome for any potential victims.
Our due diligence processes
We plan to continue to send the Modern Slavery Supplier Questionnaire to new higher risk suppliers and annually review any existing suppliers assessed as higher risk. If requested, our suppliers will provide data to support Local TV’s Modern Slavery programme.
Key Performance Indicators linked to modern slavery and human trafficking
The table below outlines our Key Performance Indicators, progress to date and future plans.
|KPI||Progress to date||Future plans|
|Extend training to all relevant staff via an e-learning exercise to raise awareness of modern slavery and human trafficking and help staff to recognise the signs and mitigate this||We developed an e-learning exercise for all staff, which aims to ensure that modern slavery is widely recognised and understood through the business, this was rolled out last year||Review learning materials to ensure they are up to date and adapt to conform with changes to law and policy. Re-issue training to all relevant staff|
|Maintain a Modern Slavery policy outlining Local TVs approach to reducing the likelihood of modern slavery in its supply chain||We have developed a Modern Slavery policy which applies to all Local TV employees and freelancers||This policy will be reviewed and updated on an annual basis to ensure ongoing relevance|
|Ensuring our supplier on-boarding process includes safeguards around modern slavery risk||Standard supplier terms and conditions state supplier obligations to conform to our modern slavery policy and highlighting our right to review/assess this compliance||To continually review integration of our Modern Slavery policy and controls into future improvements to supplier onboarding processes|
|Maintain a due diligence process for high risk suppliers to mitigate risk of modern slavery||Due diligence process enhanced as above, improving supplier risk assessment||Continue to send the Modern Slavery Supplier Questionnaire to new high-risk suppliers and annually assess any existing higher risk suppliers|
We developed an e-learning exercise for all relevant staff, with the aim of ensuring that modern slavery is widely recognised and understood within the business. On completion of the training, participants should be able to:
- Explain what modern slavery is and identify the different types that exist
- Understand the UK Modern Slavery Act
- Recognise the signs / indicators of Modern Slavery
- Know what actions to take should instances of modern slavery be witnessed or suspected
This training will be reviewed each year and re-issued to relevant staff as appropriate.
This statement has been approved by the board of directors on 29th January 2021