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Modern Slavery and Human Trafficking Statement

This statement applies to Digital Workplace Forum Group Limited and Digital Workplace Group USA Inc. trading as Digital Workplace Group (referred to in this statement as “DWG”). The information included in the statement refers to the financial year 2023.

A) ORGANISATIONAL STRUCTURE AND BACKGROUND

DWG was founded in 2002, originally known as the Internet Benchmarking Forum, to benchmark intranets and enable peers to connect and share best practice in a confidential setting. Since then DWG has developed to cover all aspects of the evolving digital workplace industry through membership, benchmarking and consultancy services. DWG provides expert advice, peer connections, research and insights to guide and support organizations globally on their journey towards digital workplace success. 

Demand for DWG’s services are consistently high throughout the year and are not seasonal. There is no centralised office and DWG’s business is conducted remotely in a secure digital workspace. DWG is led by a Board of Directors which comprises of the Chief Executive Officer; Chief Creative Officer and Founder; Chief Operating Officer and Chief Financial Officer. 

DWG’s employees are based largely in the United Kingdom apart from the Chief Executive Officer who is based in the U.S. DWG also uses a mix of experienced professional consultants who are engaged based on their specific expertise to allow DWG to operate the business. As such, DWG’s own business operations and supply chain consists primarily of homeworking professionals with minimal exposure to areas with a modern slavery risk.

B) DEFINITIONS

DWG is committed to social and environmental responsibility and to the fair and humane treatment of people in its employment and in its supply chains. DWG considers that modern slavery encompasses:

  • Human trafficking;
  • Forced work, through mental or physical threat;
  • Being owned or controlled by an employer through mental or physical abuse or the threat of abuse;
  • Being dehumanised, treated as a commodity or being bought or sold as property;
  • Being physically constrained or to have restrictions placed on freedom of movement.

C) COMMITMENT

DWG under its Board of Directors acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. DWG understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

DWG does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. 

No labour provided to DWG in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. DWG strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the UK and the U.S.

D) SUPPLY CHAINS

In order to fulfil its activities, DWG’s main supply chain includes global professional cloud-based service companies as well as experienced professional consultants engaged based on their specific expertise to allow DWG to operate the business. Whilst DWG acknowledges that it does not have control over the conduct of individuals and organizations within the supply chain, DWG expects the same standard of conduct from all people with whom it conducts business or those who act on behalf of DWG. 

E) POTENTIAL EXPOSURE

DWG has assessed the risks, both external and internal, within DWG’s own operations and in its supply chain and DWG considers its exposure to slavery/human trafficking to be no or low risk. Nonetheless, DWG has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it. Where any high risk is identified appropriate due diligence is undertaken to ensure that parties concerned have in place appropriate ethical employment practices that comply with all relevant legislation, including where applicable, the making of an anti-slavery statement pursuant to legislation.

F) IMPACT OF COVID-19

During the pandemic, DWG employees continued to have access to the grievance procedure to raise any concerns that they may have had. As DWG employees were already homeworking and the work did not decrease during that period there was no need to change working practices such as changing from office to a temporary period of homeworking. DWG’s modern slavery risk assessments were subject to the same monitoring procedures during the pandemic as at all other times.

G) STEPS

DWG carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers where required.

DWG has not, to its knowledge, conducted any business with another organization which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Board of Directors have overall responsibility for ensuring this policy is implemented and complied with. This includes where relevant: 

  • Determining and maintaining a zero-tolerance policy towards modern slavery approved by the Board of Directors;
  • Identifying assessing and mitigating any potential key risk areas within the supply chain that may require communication and/or process/policy review;
  • Ensuring assessment of any potential risks against current controls to identify opportunities for improvements or new action including updating supplier agreements, engaging key suppliers based on risk and determining whether it is appropriate for a business relationship to continue or terminate;
  • Modifying internal policies and procedures based on risk; 
  • Ensuring the management team are responsible for abiding by this policy and know how to address any relevant concerns raised by an employee/s;
  • Relevant staff training as necessary to ensure staff awareness of how to treat others and compliance with policies and procedures in an ongoing due diligence process and managing any misconduct accordingly;
  • Keeping records and reporting where appropriate.

H) POLICIES

DWG has the following policies which further define its stance on modern slavery as well as promote ethical business conduct. DWG’s policies contributing to this commitment preventing violations of human rights include:

  • Modern Slavery and Human Trafficking Policy;
  • Whistle Blower Policy;
  • Anti-bribery Policy;
  • Personal Harassment Policy and Procedure;
  • Equal Opportunities Policy.

I) TRAINING 

DWG provides awareness to staff by making the policy available through our HR system and compliance Teams area to all employees.

J) SLAVERY COMPLIANCE OFFICER

DWG has a Slavery Compliance Officer, Helen Day, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to DWG’s obligations in this regard.  

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval 4th June 2024

Helen Day Chief Operating Officer

 

Modern Slavery and Human Trafficking Policy

A) INTRODUCTION

Digital Workplace Forum Group Limited and Digital Workplace Group USA Inc. trading as Digital Workplace Group (“DWG”) is committed to ensuring that all its business operations are free from involvement with slavery and / or human trafficking.

Annual statement

Although DWG does not meet the requirements of the Modern Slavery Act 2015 that would legally require DWG to produce a slavery and human trafficking statement, we recognise the importance of preventing modern slavery and therefore we will voluntarily produce an annual modern slavery and human trafficking statement. A link to this statement will be on the homepage of our website and will be signed and approved by Helen Day, Chief Operating Officer.

Helen Day is responsible for ensuring that this statement is published and reviewed on an annual basis.

The statement will explain the steps that DWG has taken to ensure that slavery and trafficking are not taking place in any of its supply chains, or in any part of its own business.

B) CONTENT OF THE STATEMENT

The following items will be included in the statement.

  1. The structure of our organisation, the business operations of the organisation and the supply chains.
  2. Our policies in relation to slavery and human trafficking.
  3. The due diligence processes that we carry out to ensure that there is no slavery or human trafficking in our business and supply chains.
  4. Identification of any parts of our business and supply chains where there is a risk of slavery or human trafficking taking place, and the steps that we have taken to assess and manage the risk.
  5. An assessment of the effectiveness of the measures that we have taken to stop slavery and human trafficking taking place, and the way that we assess and manage the risks that are identified.
  6. A statement that training about slavery and human trafficking is available to all employees.

C) ADDITIONAL ACTION POINTS

In addition to producing the annual statement, DWG is committed to:

  • ensuring that slavery and human trafficking is considered and addressed in our approach to corporate social responsibility
  • ensuring that any concerns about slavery or human trafficking can be raised through our whistleblowing procedure
  • carrying out regular audits to ensure that all our UK employees are paid at least the National Minimum Wage and have the right to work in the UK
  • appointing a named individual, Helen Day, to oversee the compliance with the Modern Slavery Act 2015
  • identifying and addressing any areas of high risk in our supply chain
  • providing training as required for all employees who are involved in the supply chain on issues relating to slavery and human trafficking.