Modern slavery is a heinous crime and a morally reprehensible act that deprives a person’s liberty and dignity for another person’s gain. ELLA Digital has a zero-tolerance approach to Modern Slavery and is fully committed to preventing slavery and human trafficking in our operations and supply chain. As a company we are committed to protecting our organisation and those people at risk from exposure to slavery or human trafficking in our supply chain, both via our direct employees and those working on our behalf via third party suppliers.  

Organisational Structure and Background​ 

ELLA Digital is headquartered in Tunbridge Wells, England with offices in London operating under a portfolio of partners and brands. This statement relates solely to ELLA Digital and all the entities that it represents 

Our Colleagues 

Our colleagues are all provided with a written contract of employment as well as access to a company handbook which contains any policy that governs their employment. Each colleague has a personal responsibility to read the handbook, as well as to ensure that they fully understand our obligations and the consequences associated with any breach of those obligations. We are committed to uncompromising integrity in all that we do and how we relate to each other and to our customers. 

It is a fundamental policy of ELLA Digital to conduct business with honesty and integrity and in accordance with the highest standards of ethics, equality and fair dealing. We appreciate the key role that ELLA Digital employees play in maintaining high standards and ensuring as a business we are compliant in all aspects of regulations set forth by the UK Government.  

We provide a confidential whistleblowing helpline that encourages our colleagues to report any concerns related to the direct activities, or the supply chain of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. These reports are reviewed by the most senior directors of ELLA Digital. 

Our Third Party Supply Chain 

The breadth, depth and interconnectedness of our technology supply chain make it challenging to effectively manage and mitigate the risk of modern slavery. We also recognise that the nature of the technology industry is such that our supply chain for software and services is multifaceted as any given solution will have its own supply chain. We’re keen to engage with our suppliers to ensure that they match our high standards and the ethos of the Modern Slavery Act 2015 and filter this message down throughout their own supply chain. 

ELLA Digital is committed to ensuring there is transparency in our own business and in our approach to tackling Modern Slavery throughout our supply chains and expect the same high standards from all our contractors, suppliers and other business partners. We establish a relationship of trust and integrity with all our suppliers, which is built on mutually beneficial factors. The use of service provider contractors in our organisation is largely within our facilities support area but not limited to this part of our business. ​ 

Due Diligence 

ELLA Digital continues to take its responsibilities seriously and whilst building on the actions already in place, we will continue to look for more ways to fortify our method of identifying and mitigating the risk of Modern Slavery. 

Our Approach: 

• Continue to assess the risk of slavery and trafficking into our supplier due diligence process for areas of the business we deem to be higher risk; this due diligence includes requiring them to complete questionnaires on their own policies concerning the issue. 
• Continue to issue our Modern Slavery Policy and Supplier Code of Conduct that highlights the standards of compliance expected. Third party suppliers and contractors we deem to be higher risk are required to sign to say that whilst carrying out its obligations to ELLA Digital they shall comply and seek to ensure that each of its own subcontractors and suppliers involved in the provision of goods and services will comply with the documentation. 
• Continue to provide e-Learning training for Management to enable them to identify, assess, mitigate and report specifically on Modern Slavery. 

• Continue to publish our Modern Slavery Policy within our employee handbook. 
• Continue to ensure that our confidential employee reporting hotline is clearly promoted in all of our sites. 
• Continue to conduct supplier audits on companies we deem to be higher risk. Audits include visiting supplier registered offices and requiring visibility to relevant paperwork that gives us confidence and reassurance that those employed are not subject to Modern Slavery in any form. 

Whilst ultimately the majority of risks within the business rest with our suppliers, we are not complacent and will continue as a Company to seek to identify and manage any potential risks associated with Modern Slavery. We have endeavoured to put safeguards in place to ensure, so far as is reasonably practicable, that the working practices of those employed directly by us and those with whom we have a direct contractual arrangement with also have a similar zero tolerance to Modern Slavery. 

This statement is made pursuant to section 54 of the Modern Slavery Act 2015.