Modern Slavery Statement
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The expressions used to simplify agreements:
This Modern Slavery Statement (“Statement”) is an agreement between Atmostfear Entertainment S.A.S. (“us”, “we”, “our” or “ours”) and you (“user”, “you”, “your” or “data subject”).
We provide our Network, including all information, tools and services available to you, the user, conditioned upon your acceptance of all terms, conditions, policies and notices stated here.
We are committed to protecting and respecting human rights and have a zero-tolerance approach to slavery and human trafficking in all its forms.
This statement is made according to Section 54, Part 6 of the Modern Slavery Act 2015 and sets out the steps this organisation has taken and will take concerning slavery and human trafficking.
Structure, and Activities
Our organisation partially adopted the Universities (Scotland) Acts 1858 to 1966.
We educate students, scholars, and researchers from all over the world and seek to invite, promote, reward and retain the best staff for a world-class publishing and research institution.
Many of our staff work internationally, and some are based, or spend significant proportions of their time, working at facilities overseas.
These international facilities include liaison offices in Colombia, the United States of America, and Portugal; and collaborative ventures (warehouses, research, outreach) in the United Kingdom.
As a truly global enterprise, we make a significant, sustainable and socially responsible contribution to the world.
We recognise that modern slavery is a significant global human rights issue and includes human trafficking (for domestic or sex work and other forms of labour), forced and bonded labour, some forms of child labour, and domestic servitude.
Our commitment starts by protecting and respecting human rights and taking action to prevent slavery and human trafficking in all its forms.
We will act ethically and with integrity in all our relationships, and use all reasonable endeavours to take action directly and within our sphere of influence to ensure slavery and human trafficking is not taking place.
We are committed to continuing to carry out research and offer to teach on modern slavery.
We purchase a wide range of goods and services, following public procurement law and our ethical sourcing principles and practices.
These include technical services and supplies, clothing, jewellery, home decor, stationery material, electronics, footwear and jewellery supplies, books and printing services.
A large proportion is bought through frameworks established by collaborative consortia.
Due to controls and systems that our enterprise has in place, the risk of modern slavery on our facilities is low. However, we recognise that there are risks linked to global supply chains related to the goods and services that we procure and that modern slavery is usually hidden.
Additionally, given the global reach of our organisation, we recognise that there are potential risks of modern slavery occurring related to our international activities, primarily when located in high-risk countries.
We work with others, including scholars, researchers, journalists, photographers, merchants, procurement bodies and civil society organisations, and government agencies, to share information and mitigate risks.
Policies and Practices
Our Human Resources Policies set out our commitment to workplace rights at the organisation.
We are rigorous in checking that all recruits have the right to work in the country.
Where it is necessary to hire agency workers or contractors, our staff are directed to specified, reliable agencies that have been vetted through the organisation’s rigorous procurement procedures and met the imposed selection criteria regarding their business and employment policies and practices.
For example, agencies are asked to identify any sub-contractors and to promote “fair work” practices, as appropriate.
Our Dignity and Respect Policy promotes an enabling and inclusive environment in which all members of the organisational community are treated with dignity and respect, and bullying, harassment and discrimination are known to be unacceptable.
We adhere to The Public Interest Disclosure Act 1998 and implements its own Whistleblowing Policy regarding concerns about potential corruption, fraud or other unlawful practices within the organisation.
If any modern slavery cases were to be suspected on-site, any alleged violation of human rights would be fully investigated, and appropriate disciplinary action would be taken against any member of staff found to have acted unethically and in breach of the organisation’s commitment to human rights.
We have a published Organisational Procurement Strategy which displays our principles and practices in the acquisitions of goods, services, and building works and outlines how we take steps to ensure an ethical procurement approach.
We have adopted the Supply Chain Sustainability Policy, which promotes the Ten Principles of the UN Global Compact.
In asking relevant suppliers to adopt the Supply Chain Code of Conduct, we collaborate with others to demonstrate a commitment not to use force, involuntary or underage labour.
Other related policies include our Conflict Minerals Policy, our Fair Trade Policy, and our statutory duty to consider “fair work” practices appropriately, supporting social responsibility locally and globally.
To identify and assess potential risk areas in our supply chains, we use the Life Cycle Mapping approach (based on United Nations precedents), to assess prioritised categories (travel, electronics, food and catering, laboratory supplies, building supplies).
Briefing papers summarising the category risks and opportunities have been produced, and action plans made.
Modern slavery is highlighted as a risk throughout, and appropriate questions to ask bidders or suppliers during the procurement process are recommended.
The process leads to action points for different groups in the organisation, including procurement actions, research questions and operational changes to consider.
As the first Colombian organisation to fully make use of these practices, we share our learning with others and have invested resources in developing the practices further.
Through a sustainable database, suppliers are asked to provide details of measures they take concerning modern slavery in their supply chain, including any third party accreditations and assessments to evidence this.
Where risks have been identified, we work with other consortia, or directly, to raise social responsibility questions including human rights issues at contract management meetings with our key suppliers, assess publicly available reports from companies, and follow-up on any concerns we identify.
We provide details of the factories in which the products we buy are produced, according to our suppliers, and we work with civil society organisations in the countries where the factories are located to monitor working conditions.
If evidence is found indicating modern slavery in our supply chains, we recognise our responsibility to work with others to address this.
The organisation, in some instances, will have the right to terminate contracts where serious violations are discovered.
Fundraising, and Investments
We work to screen philanthropic donations to ensure they do not come from unethical sources.
All proposed donations of €5,000 or more are subject to due diligence by Development and Alumni, including searching for any connection to modern slavery.
The extent of due diligence and oversight applied will increase in line with an assessment of the risk associated with the potential donor and potential size of the donation.
Donations of more than €500,000 will be subject to a full due diligence review and risk assessment by Development and Alumni and are automatically referred to the Organisation’s Ethical Fundraising Advisory Group.
Our Responsible Investment Policy Statement summarises the approach of the organisation concerning investments.
All of our fund managers are PRI signatories and share a commitment to assess ESG concerns (including human rights issues such as modern slavery) in our investments.
Identification and Mitigation
We have drafted specific terms to be inserted in the organisation’s purchase contracts which will require suppliers to:
– comply with the United Kingdom’s Modern Slavery Act 2015 and all other applicable laws regarding anti-slavery and human trafficking;
– maintain policies to ensure compliance;
– perform due diligence on their supply chains and include anti-slavery and human trafficking provisions in such supply contracts;
– notify the organisation of any breaches and provide the organisation with annual compliance reports.
We are aiming to include these terms in the organisation’s standard Terms and Conditions of Purchase by the end of 2020.
We have contacted our suppliers to ask about their modern slavery efforts and the related issue of conflict minerals.
We have begun to assess where we can best help suppliers improve their approaches.
We are supporting further work to develop and implement the sustain supplier database to increase the number of suppliers completing the questionnaire and providing evidence of their efforts and progress.
We researched our supply chains and construction suppliers’ approaches to modern slavery and the extent of their compliance with the Act.
115 (one hundred and fifteen) suppliers were assessed, based on the information they had made publicly available. The research report has been used internally to identify suppliers to engage further with regarding modern slavery.
We have continued to identify risks and prioritise actions regarding our supply chains in particular.
Training, and education:
Awareness, and Training
As a community of over 30 staff and 2,818,932 followers and a place of education, we recognise our responsibility to raise awareness on this crucial issue and to train some groups of staff specifically on modern slavery risks and best practice.
We have prepared content on social responsibility and sustainability issues and policies, including modern slavery, to be added to our training for staff who purchase equipment, stationery and other items for their teams, which will be rolled out in the coming year.
Our staff have received training on modern slavery risks and how to take appropriate action.
Budget holders and/or approvers of financial transactions are asked to confirm their awareness and understanding of the Modern Slavery Statement (and other vital commercial policies) through the Finance Department.
Programmes, and courses:
Teaching, and Research
The organisation has continued to provide various programmes and courses that specifically examine issues of modern slavery and human trafficking.
Extensive research related to human rights including in supply chains is taking place within the organisation. A wide range of programs and research also examines historical slavery.
Our project involves research and awareness-raising — of the general public and also specifically public procurers across Latin America.
Employment, and Partnerships
While our Human Resources staff in Colombia does closely collaborate on recruitment of staff for our international offices, we have begun to explore what more can be done to mitigate any risks regarding other people working in the office’s sphere of influence internationally, such as those contracted for artisanship or tailoring services, transport or interpreters.
Awareness of modern slavery risks is being incorporated into our new Ethical Research Partnerships guidance for staff and affiliates working with other organisations and institutions overseas.
Our staff have met a few times this year, to discuss our progress on modern slavery, share relevant information, and agree on next steps.
This has engaged a wide range of staff in the issue of modern slavery and has raised awareness of potential risks and best practices within different departments.
Keeping up to date with revisions:
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This document was last updated on July 28th, 2020.