Modern Slavery Policy

The most common forms of modern slavery are as follows:

• Human trafficking: The use of violence, threats or coercion to transport, recruit or harbour people in order to exploit them for purposes such as forced prostitution, labour, criminality, marriage or organ removal.
• Forced labour: Any work or services people are forced to do against their will under threat of punishment.
• Debt bondage/bonded labour: The world’s most widespread form of slavery. People trapped in poverty borrow money and are forced to work to pay off the debt, losing control over both their employment conditions and the debt.
• Descent–based slavery: Most traditional form, where people are treated as property, and their “slave” status was passed down the maternal line.
• Slavery of children: When a child is exploited for someone else’s gain. This can include child trafficking, child soldiers, child marriage and child domestic slavery.

Introduction

At Project36, we are committed to conducting business responsibly, ethically, and with the highest standards. Modern slavery in all its forms, including forced labour, servitude, and human trafficking, is an abhorrent violation of human rights. This Modern Slavery Policy aims to ensure that no such practices occur within our organisation or supply chain.

Our Supply Chain Overview

As a purpose-driven, strategic marketing agency specialising in HubSpot service delivery and OKR methodology, Project36 works with a variety of suppliers. These range from IT vendors to marketing consultants and content providers. We recognise that each tier within our supply chain presents potential risks concerning modern slavery, and we are committed to implementing and maintaining systems that prevent it.

Code of Conduct

Our Code of Conduct mandates all employees, irrespective of their level or role, to act ethically and responsibly. We expect the same level of integrity from our suppliers and partners. The Code of Conduct applies to all sectors of our business, including procurement, partner selection, and client management.

Anti-Bribery

Project36 has zero tolerance for bribery or corruption of any sort. Offering, giving, soliciting, or accepting any form of bribe, including monetary or other inducements, can lead to immediate termination and potential legal action. This Anti-Bribery clause exists not just to protect our organisation but to secure our supply chain from practices that could encourage or perpetuate modern slavery.

Whistleblowing

Employees who have concerns about any form of malpractice can report it confidentially without fear of retaliation. This includes suspicions or evidence of modern slavery within our organisation or supply chain. We have a comprehensive whistleblowing policy in place that ensures anonymity and protects the rights of the whistleblower.

Supplier Code of Conduct

Project36 insists that all suppliers comply with this Modern Slavery Policy as part of our contract terms. Our Supplier Code of Conduct includes:

• Adherence to all applicable local and international laws concerning labour and human rights.
• Zero tolerance for modern slavery, child labour, or forced labour.
• Fair remuneration and working conditions.
• Anti-bribery and anti-corruption policies.

Failure to comply will result in a review and potentially the termination of the supplier relationship.

Human Rights Policy

We are fully committed to upholding human rights as outlined in the Universal Declaration of Human Rights. This includes, but is not limited to, the abolition of forced labour and child labour, the provision of safe working conditions, and the right to fair remuneration. Our Human Rights Policy extends to our employees, contractors, suppliers, and other stakeholders involved in our business.

Implementation and Monitoring

The implementation of this policy is the responsibility of all employees, especially those involved in procurement and supply chain management. Regular audits and assessments will be carried out to ensure compliance with this policy.

Conclusion

This Modern Slavery Policy underlines Project36’s unwavering commitment to conducting our business in an ethical and responsible manner. We expect all staff, suppliers, and partners to adhere to and act consistently with the principles stated in this document.

Last Reviewed: Sep 15, 2023

Authorised by: Joe Birkedale, CMO & Founder