Introduction 

This statement is made pursuant to S54 of the Modern Slavery Act of 2015. This statement outlines the actions that Aptimized has taken and is continuing to take to make sure that modern slavery or human trafficking is not taking place within our business or supply chain. 

Aptimized has a zero-tolerance approach to any form of modern slavery. Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. We are committed to acting ethically and with integrity and transparency in all business operations. Aptimized has implemented systems and controls to safeguard against any form of modern slavery taking place within the business or supply chain. 

We have the same expectations from all of our partners, contractors, and other suppliers. We will continue to include specific prohibitions against the use of forced, compulsory, or trafficked labour, as well as anyone held in slavery or servitude, whether adults or children, in our contracting process.

This policy applies to all individuals who work for us on our behalf in any capacity at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third parties, and business partners. 

Our policies on slavery and human trafficking 

Aptimized operates a number of internal policies to ensure that we conduct business ethically and transparently. 

These policies include: 

  1. Recruitment policy. We operate a recruitment policy including conducting eligibility to work in the UK check for all directly employed staff, and agencies on approved frameworks are audited to provide assurance that pre-employment clearances are obtained for staff, to safeguard against human trafficking or individuals being forced to work against their will. 
  2. Equal opportunities. We have controls in place to protect staff from poor treatment in compliance with all respective laws and regulations, including the provision of fair pay rates, access to training and development opportunities, and fair terms and conditions of employment. 
  3. Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated without reprisals. 
  4. Business Conduct Standards. The standards of business conduct explain the manner in which we behave as an organisation and the expectations of our employees and suppliers. 

Communication and Awareness 

Training on this policy, in addition to the threat our company faces from modern slavery, is required for all new employees. Updates will be available through established channels of communication with the company. 

Our zero-tolerance approach to modern slavery must be conveyed to all business partners from the onsight of our agreement with them and reinforced thereafter as needed. 

Policy Breaches

An employee that violates this policy will face disciplinary action, potentially resulting in dismissal as a result of misconduct. If other persons or organisations working with Aptimized violate this policy, we reserve the right to terminate our agreement effective immediately.