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Modern slavery act statement​

This statement, made pursuant to section 54(1) of the Modern Slavery Act 2015, demonstrates our commitment to tackle modern slavery and sets out the approach taken by STRAT7 Ltd. (STRAT7) to understand whether slavery, servitude, forced labour and/or human trafficking (together “Modern Slavery”) exist in our supply chain.

This statement demonstrates the actions undertaken to eliminate Modern Slavery during the financial year ended 30 June 2024, and is applicable to STRAT7 and all associated STRAT7 companies, including STRAT7 Bonamy Finch, STRAT7 Crowd DNA, STRAT7 Incite, STRAT7 Jigsaw, STRAT7 Rainmakers and STRAT7 Researchbods.

Our Business

STRAT7 is a global strategic insight and customer analytics group. We help global brands understand, predict and act on customers’ needs at pace and at scale. We blend cultural, category, and consumer understanding to create impactful customer-centric solutions that are always in-tune with changing consumer needs, to help our clients to put their customers at the heart of all decisions

STRAT7 is headquartered in the UK, with over 400 employees worldwide and offices in 4 continents. Our supply chain consists of global suppliers of AI technologies, data, research services and consultancy, office supplies and computer software and equipment.

Although the research industry may be considered low-risk, we do operate globally and, as such, recognise that it is not without risk. Therefore, STRAT7 is mindful of this and seek to address potential modern slavery risk withing our sphere of operations, where possible. We are also aware that although all but 2 of our offices are located in countries with a low Modern Slavery prevalence score of under 5, we do have offices in Bulgaria, which has a prevalence score of 8.50. Over 75% of our offices are located in top tier countries, according to Walk Free’s Global Slavery Index, in terms of best governmental response to Modern Slavery.[1]

Where necessary, we work with a network of independent contractors and other 3rd agencies, typically where specialist technical or linguistic skills are required to deliver certain contractual obligations. Whilst this constitutes a relatively small percentage of our extended workforce we are nevertheless committed to ensuring that there is no modern slavery in our such elements of our supply chain or any other part of our operations.

[1] Based on Walk Free’s Global Slavery Index, 2024

Group Policies & Procedures

Our Central Operations and People teams are responsible for implementation of policies and procedures that support the business in meeting its human rights responsibilities. This includes the following:

  • Anti-Bribery and Corruption Policy
  • Corporate Social Responsibility and Charity Matching Policy
  • Disciplinary and Grievance Procedures
  • Ethical Trading Policy
  • Equality, Dignity and Diversity Policy
  • Living Wage Policy
  • Recruitment Policy
  • Whistleblowing Policy

Expectations for Employees

Our commitment to eradicating modern slavery is emphasised in our employee training and company policies, which promote ethical behaviours. Our employees are required to abide by our codes and ethics which are set out in our Company Handbook. This includes the expectation that employees will familiarise themselves with the Modern Slavery Act Statement, remain alert to potential violations, and report instances swiftly and appropriately. The Company Handbook brings together all our policies stated above, is regularly reviewed and published internally. All staff are directed to it upon commencing employment at STRAT7.

Additionally, Modern slavery awareness training is now a required new starter training module at STRAT7, and our HR Department ensures all new staff complete the training by tracking progress via our online training portal. By Autumn 2024 this will also be one of our required annual refresher training modules too.

Expectations for Suppliers

STRAT7 expects the same high standards which we set for ourselves from those parties with whom we engage, such as our suppliers and customers. We maintain a Supplier Approval Process to assess a potential supplier’s suitability and alignment with our standards and values. From the 2023/24 Financial Year STRAT7 is taking steps to include appropriate questions and/or requirements to be met in our supplier assurance vetting process. As part of this process, we will assess whether they operate lawfully and ethically and take this into consideration when choosing our suppliers or renewing our relationship with existing suppliers.

During the course of this financial year STRAT7 will commence upon a programme to require all key suppliers to indicate their compliance with our Partner Code of Conduct which expects that the supplier to maintain one or more policies stating their commitment to eliminate Modern Slavery from their supply chains. The Partner Code includes expectations for the prohibition of modern slavery and child labour; fair and ethical working hours, conditions, and environments; and commitments to freedom of association and non-discrimination.

 

Board Oversight

STRAT7’s Board is committed to delivering high standards of corporate governance and managing our Company in a socially responsible and ethical way. We aim to comply with all local laws and regulations applicable to our business and we are equally committed to preventing Modern Slavery in its activities and supply chain.

Speaking Up

Employees, suppliers, and any other stakeholders are expected to immediately report any suspected incident of modern slavery in STRAT7’s direct operations or supply chain. Concerns can be confidentially reported to our Group Operations Director, members of our HR Dept. their line managers, or through an independent third-party organisation.

Areas for Improvement

Whilst we have a supplier management system in place, we know that progression is always possible in how we assess and monitor existing and new suppliers alike, to ensure compliance with our expectations, values and practices. Equally, we recognise that we can make improvements in our upward assessments of the clients we choose to work with.

STRAT7 is very much committed to improving our ethical trading standards and in the previous financial year actively chose to pursue B Corp accreditation, which we are continuing to work towards. An update on our progress against this stated aim will be included in our next Modern Slavery statement.

In the meantime, we will continue to review the suitability and efficacy of relevant policies and procedures, to ensure they remain fit-for-purpose.

At present we do not have a corporate key performance indicator in relation to combatting Modern Slavery specifically, however as we strive to achieve B Corp status this will be reviewed and updated as appropriate in future statements.

We will provide an update on these actions in the revision of our Modern Slavery Act Statement in July 2024.

This statement is approved by the Board and signed on its behalf by:

Barrie Brien

CEO

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