Modern Slavery and Human Trafficking Policy

1. Policy Statement 

Plug and Play Limited, trading as Plug & Play Design ("the Company", "we", "us"), is committed to acting ethically and with integrity in all our business relationships. We have a zero-tolerance approach to modern slavery, forced labour, servitude, human trafficking, and any form of exploitation of workers, and we are committed to acting to prevent these occurring in our own business and throughout our supply chains. 

Although we are a small, UK-headquartered digital services business with a low inherent risk profile, we recognise that modern slavery is a global issue and that no organisation is entirely without risk. This policy sets out our commitment and the steps we take to understand, prevent, and address that risk. 

2. Purpose and Scope 

This policy applies to: 

• All directors, employees, and workers of Plug and Play Design Limited and Plug & Play Design, whether permanent, fixed-term, or temporary; 
• All contractors, freelancers, and consultants engaged by the Company, wherever they are based; 
• All third-party suppliers, vendors, and service providers we engage with, including technology and software providers; 
• All business relationships entered into by the Company, in the UK and in any country in which we operate or engage suppliers. 

The purpose of this policy is to communicate our commitment, define responsibilities, and describe the practical steps we take to identify and mitigate modern slavery risk. 

3. What is Modern Slavery? 

"Modern slavery" is an umbrella term covering slavery, servitude, forced or compulsory labour, and human trafficking, as defined under the UK Modern Slavery Act 2015. In practice this includes: 

• Slavery: where ownership is exercised over a person. 
• Servitude: obligation to provide services imposed by coercion. 
• Forced or compulsory labour: work extracted under threat of penalty, performed involuntarily. 
• Human trafficking: arranging or facilitating the travel of another person with a view to exploiting them. 

Indicators can include withheld wages or identity documents, excessive or unpaid overtime, unsafe or degrading working conditions, restricted freedom of movement, and debt bondage or recruitment fees charged to workers. 

4. Our Commitment 

We commit to: 

• Never engaging in, and never knowingly facilitating, any form of modern slavery or human trafficking; 
• Maintaining recruitment and employment practices that respect the rights and dignity of all workers; 
• Exercising proportionate due diligence over the suppliers and third parties we engage; 
• Encouraging employees, contractors, and suppliers to report any concerns without fear of reprisal; 
• Reviewing and improving this policy and our practices on an ongoing basis. 

5. Our Business and Supply Chain 

Plug & Play provides digital marketing, web design, and app design services. We operate primarily from the UK, with a team of around 20 employees and contractors, the large majority of whom are based in the UK and work directly with us under standard employment or contractor agreements. 

Our supply chain is limited in complexity. We do not manufacture goods, operate in high-risk sectors such as agriculture or construction, or use labour agencies. Our principal third-party relationships are with established technology and software providers (for example, cloud hosting, design, and productivity platforms) used to deliver client work. We consider our inherent modern slavery risk to be low, but we keep this assessment under periodic review as the business grows or as we engage new types of suppliers or overseas contractors. 

6. Recruitment and Employment Practices 

To ensure modern slavery risk does not arise within our own workforce, we: 

• Verify the right to work in the UK (or relevant jurisdiction) for all employees and contractors before engagement; 
• Pay all workers directly, on time, and at or above the applicable National Minimum/Living Wage or equivalent local standard; 
• Never charge recruitment fees to candidates or withhold identity or travel documents; 
• Ensure all employment and contractor terms are set out in written agreements that workers can freely enter into and end in accordance with notice provisions; 
• Provide safe, fair working conditions in line with UK employment law and, where team members are based abroad, applicable local law. 

7. Supplier and Third-Party Due Diligence 

Given our low-risk operating model, our due diligence is proportionate to risk. Where we engage new suppliers or contractors, particularly any based outside the UK or engaged through an agency, we will, as appropriate: 

• Consider modern slavery risk as part of standard supplier onboarding; 
• Include an expectation of compliance with modern slavery and human trafficking laws in supplier or contractor terms where relevant; 
• Seek reassurance from higher-risk suppliers (e.g. those using overseas labour or subcontracting) regarding their own policies and practices; 
• Reassess a supplier relationship if credible concerns about labour practices come to light. 

We do not currently consider our major technology suppliers (such as cloud, software, and platform providers) to present material modern slavery risk given their scale, public reporting obligations, and nature of service; this assessment will be revisited if our supplier base changes. 

8. Raising Concerns 

Any employee, contractor, supplier, or other individual who has concerns or suspicions that modern slavery or human trafficking may be occurring within our business or supply chain should raise this promptly. 

• Concerns can be raised, in confidence, with any of the Plug & Play Management Team 
• No individual will suffer any form of detriment or retaliation for raising a genuine concern in good faith, even if it later transpires that the concern was mistaken. 
• Concerns will be investigated promptly and appropriately, and escalated to the relevant authorities (for example the Gangmasters and Labour Abuse Authority or the police) where warranted. 

9. Monitoring and Review 

If, in a future financial year, our (or our group's) annual turnover approaches or exceeds £36 million, we will assess whether we are required to publish an annual statutory slavery and human trafficking statement under Section 54 of the Modern Slavery Act 2015, and adapt our approach accordingly. 

Conclusion

At Plug & Play, we take our responsibility to combat modern slavery and human trafficking seriously, across our own operations, our supply chains and the communities we work within. We are committed to acting with transparency, upholding ethical standards in everything we do, and continually reviewing and strengthening our practices. Through this ongoing commitment, we aim to play our part in building a world where exploitation and inhumane treatment have no place.

For any further questions or clarifications regarding this policy, please contact [email protected]