Anti Modern Slavery Statement

Max Communications Ltd

This statement sets out Max Communications Limited (Max) – actions to understand all possible modern slavery risks related to its business activities and to implement measures that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. As an initial statement, this statement relates to actions and activities during the current financial year (1st Aug 2019 to 31st July 2020).

For the avoidance of doubt, Max is unequivocally committed to preventing slavery and human trafficking in its activities, and to ensure that our supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

Max is a UK based digitisation services provider, focused on delivering high-quality digitisation solutions to its customers. We deliver a range of digitisation and other services including but not limited to digitisation, digital preservation, digital archive management, project management and digital archiving of family histories.

Applying multidisciplinary expertise and deep industry knowledge, Max work with predominantly UK clients in a range of market sectors, including the heritage sector, education, and others.

The following is the process by which the Max assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking:
Max operates a supplier policy and undertakes due diligence on all our suppliers. The due diligence includes a statement that each supplier is required to complete to show that the organisation:

• complies with the Modern Slavery Act;
• takes steps to eradicate modern slavery from their business
• holds their own suppliers to account over modern slavery
• Ensures their workers receive the minimum wage and undertake robust immigration checks

We may terminate the contract at any time should any instances of modern slavery come to light.

Max does not consider it operates in high risk sectors or locations as we currently only operate within the UK and rarely purchase outside of the UK.

Relevant Policies

• Supplier/Procurement: Max has a documented process for the sourcing and approval of third party suppliers to the organisation and has an Approved Supplier Register which documents all third party suppliers to the business. Suppliers are asked to complete an annual compliance statement to confirm their standards and compliance in quality, environmental aspects, health and safety, Modern Slavery Act, information security, equal opportunities and recruitment.
• Grievances: Max has a documented Grievance Procedure for the reporting of unlawful discrimination in any form.
• Learning and Development: Max has a Learning and Development Policy to ensure the required development of staff through communication and training opportunity.
• Whistleblowing policy: The organisation encourages all its workers to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistle blowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
• Anti slavery policy: This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where to go for help.
• Employee code of conduct: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• conducting supplier audits or assessments through the organisation’s own staff, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans;
• invoking sanctions against suppliers that fail to improve their performance in line with an – action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Performance indicators

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation:

• has a system for supply chain verification, whereby the organisation evaluates potential suppliers before they enter the supply chain; and
• reviews existing supply chains to ensure ongoing compliance.

Awareness-raising programme

As well as training ‘key’ staff, the organisation is also raising awareness of modern slavery issues by developing information for cascading and circulating in our employee newsletter known as Informed.

• the basic principles of the Modern Slavery Act 2015;
• how employees 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.

Director Approval

This statement has been approved by the organisation’s Board of Directors who will review and update it annually.