Modern Slavery Policy
Introduction
This statement sets out Sermidigital S.r.l.'s actions to understand all potential modern slavery risks related to its business and to put in place steps aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 2019.
Sermidigital S.r.l. recognises that it has a responsibility to take a robust approach to slavery and human trafficking. While we believe that our commercial activities pose a low risk in this regard, the organisation is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.
Organisational structure and supply chains
As noted above, as a company we believe our commercial endeavours are low risk from the perspective of modern slavery, as Sermidigital S.r.l. activities are mainly based in Italy and are staffed and produced in line with Italian employment and broadcasting regulations.
Risk assessments are carried out for each production or service and include an evaluation of the risk of slavery and human trafficking. The most likely risk within Sermidigital S.r.l. could arise from foreign filming, in relation to the engagement of international fixers; the relevant company policies set out below ensure any such risk is identified and minimised.
Relevant policies
Sermidigital S.r.l. operates the following policies that describe its approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in its operations:
1. Whistleblowing policy
Sermidigital S.r.l. encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains, 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 workers to make disclosures, without fear of retaliation.
2. Anti-Corruption policy
Sermidigital S.r.l. is committed to promoting high standards of business integrity. No Sermidigital S.r.l. employee may engage in corruption in any part of the world. Corruption includes bribery and giving or receiving an advantage in return for improper conduct. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. Any engagements for international fixers or experts (or any other self-employed workers) are sourced through reputable industry resources.
3. Living Wage
Sermidigital S.r.l. is committed to ensuring that all employees, including any work-experience placements, are paid at least the Living Wage.
4. Suppliers
Sermidigital S.r.l. is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Should any areas of non-compliance be identified, suppliers must permit Sermidigital S.r.l. to review and execute an improvement plan, and the company may terminate the contract should they fail to comply with these obligations.
Should anyone engaged by Sermidigital S.r.l. have any concerns whatsoever regarding modern slavery, they can speak confidentially to the CEO, who will investigate and take steps to rectify or minimise the risk of any potential issues. This statement was approved and will be reviewed annually.