Modern Slavery Policy

1. Introduction

The Goldsmiths’ Company is committed to operating with integrity, fairness, and transparency in all business activities. As an employer, procurer of goods and services, and steward of public trust, the Company recognises its responsibility to prevent modern slavery, human trafficking, forced labour, and exploitation within its operations and supply chains.

This policy outlines the Company’s approach to identifying, mitigating, and responding to risks related to modern slavery. It also sets out the responsibilities of staff, management, and suppliers in ensuring the highest ethical standards.

This policy applies to all employees, contractors, agency workers, suppliers, and third-party representatives acting on behalf of the Goldsmiths’ Company.

2. Purpose and Scope

The purpose of this policy is to:

• Establish a zero-tolerance approach to modern slavery and human trafficking.

• Ensure compliance with the Modern Slavery Act 2015 and associated guidance.

• Provide a framework for identifying and managing modern slavery risks.

• Promote responsible working practices throughout the supply chain.

• Support reporting, investigation, and remediation of concerns.

Ethical sourcing considerations relating to acquisitions, collections or external exhibitors fall outside the statutory scope of this policy and are managed through separate procurement or curatorial governance as appropriate.

This policy covers:

• All Company staff at all levels

• All suppliers, service providers, and contractors

• All procurement and commercial arrangements

• All Company-controlled premises and business activities

3. Governance and Responsibilities

3.1 Organisational Ownership

Responsibility for this policy sits with the Director of Operations, supported by HR, and senior leadership.

3.2 Management Responsibilities

Managers are responsible for:

• Implementing controls to prevent modern slavery

• Ensuring staff are aware of reporting routes

• Supporting investigations and corrective actions

• Maintaining a culture of ethical and transparent conduct

3.3 HR Responsibilities

The HR team is responsible for:

• Conducting legal work eligibility checks

• Ensuring fair recruitment processes

• Providing staff with appropriate training

• Maintaining employee reporting channels

3.4 Procurement Responsibilities

The organisation does not operate a centralised procurement function. All procurement activity is therefore undertaken at departmental level. For clarity, this policy establishes that each Head of Department (HoD) holds full accountability for the procurement of goods and services within their department.

Procurement personnel must ensure:

• Supplier due diligence is completed and documented

• Modern slavery clauses are included in contracts

• Suppliers meet ethical and legal standards

• Non-compliant suppliers are escalated or removed

3.5 Employee Responsibilities

All employees must:

• Report concerns or suspected cases of modern slavery

• Comply with this policy and related procedures

• Complete mandatory training as required

4. Legal Compliance and Ethical Principles

The Company complies with the following legislation and standards:

• Modern Slavery Act 2015

• UK employment legislation

• Ethical procurement and safeguarding standards

• Internal governance frameworks

We are committed to ensuring that:

• All work is voluntary

• No worker pays recruitment fees

• Employment terms are fair and transparent

• Working conditions meet required safety and welfare standards

5. Due Diligence and Supply Chain Controls

The Goldsmiths’ Company undertakes a risk-based approach to supply chain due diligence. This includes:

• Assessing suppliers according to their risk profile

• Mandating compliance with our ethical and legal standards

• Requiring suppliers to confirm they operate free from modern slavery

• Conducting periodic audits, checks, or reviews where appropriate

• Monitoring higher-risk categories (e.g., construction, cleaning, catering, security)

Where risks are identified, the Company will:

• Investigate promptly

• Work with suppliers to implement remedial actions

• Suspend or terminate relationships where necessary

6. Reporting Concerns

The Company encourages openness and supports anyone raising genuine concerns.

Concerns may be reported to:

• Line Managers

• HR Department

• Director of Operations

• Whistleblowing routes (where applicable)

Reports will be treated confidentially, investigated promptly, and handled sensitively. No individual will suffer retaliation for reporting in good faith.

7. Training and Awareness

To ensure effective understanding and compliance, the Company will:

• Provide modern slavery awareness training to all staff

• Deliver enhanced training to higher-risk areas (e.g., procurement, HR, contractors)

• Share periodic reminders through internal communications

• Maintain accessible guidance on recognising signs of modern slavery

• Provide supporting tools and resource to assist managers in fulfilling their responsibilities.

8. Monitoring, Review, and Continuous Improvement

The Director of Operations and HR will:

• Review this policy annually

• Monitor compliance across departments and suppliers

• Record actions taken to mitigate risks

• Identify opportunities for strengthening controls

Where changes in law or best practice arise, the policy will be updated accordingly.

9. Breach of Policy

Any breach of this policy is taken seriously. Consequences may include:

• Disciplinary action, up to and including dismissal

• Termination of supplier contracts

• Reporting to law enforcement or regulatory bodies

The Company will cooperate fully with relevant authorities during investigations.

10. References

This policy is informed by the following official UK Government publications:

1. Modern Slavery Act 2015
   Part 1 (Offences) and Section 54 (Transparency in Supply Chains)

2. Home Office “Modern Slavery: Statutory Guidance for England and Wales” (2021)
   Issued under Section 49 of the Act

3. Home Office “Transparency in Supply Chains: A Practical Guide”
   Guidance for organisations on reporting and due diligence

4. GOV.UK “How to Write a Modern Slavery Statement” (2023 update)
   Official guidance on structure, content, and compliance