Modern Day Slavery Act 2015
MBA Group is committed to preventing the use of forced, bonded, indentured labour, involuntary prison labour, slavery or trafficking of people
Created: 2015
Latest Review/Update: 04/2025
Version: 2
Overview
The MBA Group Ltd Statement on Slavery and Human Trafficking establishes MBA’s commitment to preventing the use of forced, bonded, indentured labour, involuntary prison labour, slavery or trafficking of people. The Policy embodies the spirit of our Corporate Social Responsibility Policy, Human Rights Policy and Business Conduct & Ethics Code.
This Policy applies to all employees. MBA Group Ltd also expects our suppliers to maintain progressive employment, environmental, health and safety practices that meet or exceed all applicable laws and relevant codes of practice such as MBA’s Business Conduct & Ethics Code.
MBA Group Ltd is committed to respecting human rights and upholding the values and high standards of ethics expressed in our Human Rights Policy, Corporate Social Responsibility Policy and Business Conduct & Ethics Code.
MBA Group Ltd Statement on Slavery & Human Trafficking
MBA Group Ltd will not use or tolerate the use of forced, debt bonded, indentured labour, involuntary prison labour, slavery or human trafficking in its business or supply chain. This includes recruiting, harbouring, transporting, providing, receiving, or obtaining of a person for labour services, or commercial sex acts through the use of force, fraud, coercion, abduction or fraud for the purpose of involuntary servitude, peonage, debt bondage, or slavery.
There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities. All work must be voluntary.
We will not destroy, conceal, hold or otherwise deny access by employees to their identity or immigration documents, such as passports, work permits or drivers’ licenses regardless of issuing authority. The one exception is where the holding of a work permit by the employer is required by law.
Migrant workers shall not pay for their employment. Any recruiters used to source workers must comply with UK Law. The costs of recruiting and hiring, transportation (to facility and return home), or any government imposed fees shall be paid directly by the supplier. Any fees charged to the workers must be disclosed and returned to them.
Workers shall not be required to post any bond or make any deposit. The worker shall not be required to participate in any savings program unless required by law. Working conditions, pay, benefits and treatment of migrant workers must be the same as local workers. Worker dormitories contracted or provided by the supplier or a labour agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space.
MBA Group Ltd has management systems in place to monitor and track our compliance, as well as our suppliers with all of these expectations on human trafficking and slavery.
We expect our suppliers to respect human rights, including maintaining policies and procedures to prevent the use of child or forced labour. We conduct ongoing due diligence of key suppliers to ensure compliance with Section 54 of the Modern Slavery Act 2015.
Our suppliers are contractually obligated to fully comply with MBA’s Business Conduct & Ethics Code and all applicable laws. We have internal accountability standards and procedures for employees and contractors who fail to meet our expectations regarding MBA’s Business Conduct & Ethics Code. We provide induction training and access to all applicable information for our employees.
MBA Group Ltd maintains management systems to report non-compliance of potential ethical, legal or regulatory violations related to our suppliers.
1. VERSION CONTROL
1.1 04/20205: Review – no changes
2. PURPOSE OF POLICY STATEMENT
2.1 This Policy Statement is made on behalf of the Group pursuant to The Modern Day Slavery Act 2015 Section 54 (1) and comprises our slavery and human trafficking statement, is approved by the Board and signed by the Group’s CEO..
3. OVERVIEW
3.1 The Group Statement on Slavery and Human Trafficking establishes the Group’s commitment to preventing the use of forced, bonded, indentured labour, involuntary prison labour, slavery or trafficking of people.3.2 The Policy embodies the spirit of our Corporate Social Responsibility Policy, Human Rights Policy and Business Conduct & Ethics Code.
3.3 This Policy applies to all employees.
3.4 The Group also expects its suppliers to maintain progressive employment, environmental, health, and safety practices that meet, or exceed all applicable laws and relevant codes of practice such as the Group’s Business Conduct & Ethics Code and Supplier Code of Conduct.
3.5 The Group is committed to respecting human rights and upholding the values and high standards of ethics expressed in our Human Rights Policy, Corporate Social Responsibility Policy and Business Conduct & Ethics Code.
4. SLAVERY & HUMAN TRAFFICKING
4.1 The Group will not use or tolerate the use of forced, debt bonded, indentured labour, involuntary prison labour, child labour, slavery or human trafficking in its business or supply chain. This includes recruiting, harbouring, transporting, providing, receiving, or obtaining of a person for labour services, or commercial sex acts through the use of force, fraud, coercion, abduction or fraud for the purpose of involuntary servitude, peonage, debt bondage, or slavery.
4.2 There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting Group-provided facilities. All work must be voluntary.
4.3 We will not destroy, conceal, hold or otherwise deny access by employees to their identity or immigration documents, such as passports, work permits or drivers’ licenses regardless of issuing authority. The one exception is where the holding of work permit by the employer is required by law.
4.4 Migrant workers shall not pay for their employment. Any recruiters used to source workers must comply with UK Law.
4.5 The costs of recruiting and hiring, transportation (to facility and return home), or any government-imposed fees shall be paid directly by the supplier. Any fees charged to the workers must be disclosed and returned to them.
4.6 Workers shall not be required to post any bond or make any deposit.
4.7 The worker shall not be required to participate in any savings program unless required by law.
4.8 Working conditions, pay, benefits and treatment of migrant workers must be the same as local workers.
4.9 Worker dormitories contracted or provided by the supplier, or a labour agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space.
5. COMPLIANCE
5.1 The Group will monitor and track our compliance through our business management systems and our own professional resource:
• The Group maintains a Legal Register for Health & Safety and Environmental aspects.
• Human Resources Management Information System providing visibility of hours and pay rates.
• Qualified Human Resources Function, responsible for compliance with Employment Law and associated Group Policies.
• In-house legal counsel.
6. SUPPLY CHAIN
6.1 The Group expects its supply chain to uphold the same values as we do within the Group and be compliant with UK and Local Law.
6.2 We expect our suppliers to respect human rights, including maintaining policies and procedures to prevent the use of child or forced labour.
6.3 We conduct ongoing due diligence of key suppliers to ensure compliance with Section 54 of the Modern Slavery Act 2015.
Modern Day Slavery Act 2015 Policy Statement
MBA Group Ltd, MBA House Garman Road, London, N17 0HW, Company No. 02343859 | VideoSmart Ltd, MBA House Garman Road, London, N17 0HW Company No. 02008890 |
Mabble Marketing Ltd, MBA House Garman Road, London, N17 0HW Company No.14462208 | Studio Certain Ltd, MBA House Garman Road, London, N17 0HW Company No. 13146112
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6.4 Our suppliers are contractually obligated to fully comply with the Group’s Conduct & Ethics Code and all applicable laws.
6.5 The Group’s Supplier Approval & Management Policy and Supplier Code of Conduct outlines due diligence requirements and KPI’s.
7. EMPLOYEE AWARENESS
7.1 All employees are provided with an Employee Handbook and a copy of our Business Conduct and Ethic Code during induction for which they sign a declaration.
7.2 Attention is brought to the Group’s Disciplinary Policy for failure to comply with relevant policies.
7.3 All related policies are easily accessible to all employees either through the internal central document system or their line manager.
8. NON-COMPLIANCE
8.1 We have internal accountability standards and procedures for employees and contractors who fail to meet our expectations regarding the Group’s Business Conduct & Ethics Code.
8.2 The Group maintains central management systems to report non-compliance of potential ethical, legal or regulatory violations related to our suppliers.
8.3 Actions for non-compliance will be managed through the Group’s Disciplinary Policy or Supplier Contractual Clauses.
Sami Aintaoui
Chief Executive Officer
