Anti-Slavery and Human Trafficking Policy

1. Our commitment

Cultural Data Trust C.I.C. is committed to acting ethically, responsibly and with integrity.

We do not tolerate slavery, servitude, forced or compulsory labour, human trafficking, child labour or other forms of exploitation in our own activities or supply relationships.

Our public-benefit mission is based on trust, responsible stewardship and respect for people. We expect the same standards from organisations and individuals who work with us.

2. Scope

This policy applies to the Cultural Data Trust's:

• directors and officers;
• employees, if any;
• contractors and associates;
• consultants;
• suppliers;
• technology and professional-service providers; and
• other organisations acting on our behalf where relevant.

3. Our operating context

The Cultural Data Trust is being developed to support trusted cultural data infrastructure, responsible data use, research, technology and related public-benefit services.

Our supply chain is expected to consist primarily of professional and technology services, including:

• cloud and software services;
• data and technology suppliers;
• professional advisers;
• research and consultancy;
• design and communications;
• facilities and office services;
• events and travel; and
• specialist contractors.

Although many of these activities may present a relatively low direct risk of modern slavery, we recognise that risks can exist in complex technology supply chains, outsourced services, facilities, manufacturing, equipment, hospitality and other indirect supply relationships.

4. Expectations of suppliers and partners

We expect suppliers and delivery partners to:

• comply with applicable labour, employment and modern slavery laws;
• prohibit forced labour, trafficking and exploitative working practices;
• respect workers' rights and dignity;
• take reasonable steps to understand risks within their own supply chains;
• provide information about relevant modern slavery controls when reasonably requested; and
• raise concerns promptly if they identify a material issue connected with work undertaken for us.

5. Due diligence and risk assessment

We aim to take a proportionate, risk-based approach.

This may include:

• considering the country, sector and nature of the goods or services being procured;
• reviewing publicly available supplier policies and statements;
• asking suppliers about labour and supply-chain controls;
• considering modern slavery risk when selecting material suppliers;
• escalating concerns before entering into or renewing a relationship; and
• including appropriate contractual rights or commitments where justified by risk.

6. Recruitment and working practices

Where we employ or engage people directly, we will seek to:

• comply with applicable employment and worker-protection law;
• use fair and transparent recruitment processes;
• verify the right to work where required;
• provide clear information about terms of engagement;
• ensure people are free to leave employment or an engagement in accordance with their terms and applicable law;
• prohibit the retention of identity documents as a means of control; and
• avoid recruitment practices that knowingly create exploitative debt or coercion.

7. Raising a concern

Anyone working with or for the Cultural Data Trust should raise a concern if they believe modern slavery, trafficking or exploitation may be occurring in connection with our activities or supply chain.

Concerns can be sent to:

Email: info@culturaldatatrust.org

Reports will be treated seriously and, where possible, sensitively.

No person should suffer retaliation for raising a genuine concern in good faith.

If someone is in immediate danger, contact the emergency services directly.

8. Responding to concerns

Where a credible concern is raised, we may:

• seek further information;
• suspend or review a supplier relationship;
• obtain specialist or legal advice;
• require corrective action;
• report the matter to an appropriate authority where required or justified; and
• terminate a relationship where serious concerns cannot be appropriately addressed.

Our response will consider the potential impact on affected people.

9. Responsibility

The directors of the Cultural Data Trust are responsible for oversight of this policy.

Day-to-day responsibility for procurement, supplier relationships and organisational governance should include consideration of modern slavery risk where relevant.

10. Training and awareness

We will provide proportionate information or training to people whose roles involve procurement, recruitment, contracting or supplier management where this is needed to identify and respond to modern slavery risks.

11. Monitoring and review

We will review this policy periodically and when there is a material change in:

• our size or activities;
• our supply chain;
• the services we operate;
• our risk profile; or
• relevant law or government guidance.

If the Cultural Data Trust becomes subject to statutory modern slavery transparency requirements in the future, we will prepare and publish any required statement in accordance with the applicable law.

12. Contact