Modern Slavery Statement

Submerge Limited is committed to safeguarding the wellbeing of people around the world, and takes the issue of Modern Slavery seriously. We have created this statement to show the steps we have taken to ensure we tackle the issue of Modern Slavery and identify any slavery within our supply chain and business.

Contact us via email at admin@submerge.digital if you have any questions regarding our Modern Slavery Statement.

1. Structure, business and supply chain

Submerge Limited is a content marketing agency delivering content strategies, leadership and content services to UK brands and businesses. We are serious about our brand because it’s part of our identity and so is our commitment to corporate social responsibility. We believe transparency is the best way we can ensure the public that we are doing our best as an ethical corporate citizen.

In that spirit, we have published our annual statement for slavery and human trafficking, made in compliance with section 54 of the Modern Slavery Act 2015, in which we explain how slavery and human trafficking can affect our business and the steps we are taking in the fight against it. This statement is intended to fulfil the legal requirement for a slavery and human trafficking statement on behalf of all companies within Submerge Limited and its subsidiaries, as relevant. Our efforts against slavery and human trafficking complement our broader CSR Policy.

Submerge Limited is headquartered in London, UK and sells its services exclusively to the UK. Our services are primarily digital or print, including sourcing paper, print and materials that can be manufactured and distributed across the world. Where possible, we engage suppliers who have relationships with existing suppliers so that we can contain our supplier network, such as paper and printing services, and improve consistency in ethical practices throughout the supply chain.

Building on our existing CSR Policy, we have embraced the requirement to publish an annual modern slavery statement to our web site at submergemedia.co.uk. This will allow us to share our efforts against slavery and human trafficking and improve and measure our success each financial year.

2. Slavery and human trafficking policies

We have developed our Slavery and Human Trafficking Policy, which can be found within our CSR Policy. We also created our Supplier Code of Conduct. It sets out objectives around the following themes:

• Relationships: Strengthening our supplier engagement process.

• Knowledge: Improving our knowledge base by collecting relevant data and improving product traceability.

• Third party engagement: Building strategic alliances with independent social auditors, unions and NGOs where appropriate in the future development of Submerge Limited.

• Measurable change: Developing verifiable KPIs to measure progress.

• Supplier collaboration: Encouraging suppliers to collaborate to address slavery and human trafficking issues.

• Accountability: Ensure suppliers have their own Modern Slavery Statement that is reviewed as part of any procurement process.

3. Due diligence procedures

We understand that our biggest exposure to Modern Slavery is in our product supply chains, where we will undertaken activity to minimise the risk of Modern Slavery. Within these areas, new suppliers will be subject to due diligence checks in the form of compliance audits during any procurement or exclusive contracted relationship. These audits assess compliance with the Global Sourcing Principles and are, amongst other things, intended to identify any Modern Slavery practices.

4. Identifying, assessing and managing risk

We set out to identify the extent of any slavery and human trafficking in our supply chains by:

• Reviewing supplier documentation and Modern Slavery Statements and undertaking due diligence during any procurement process;

• Not working with third party suppliers and partners that are unable to produce a Modern Slavery Statement or who are not working actively to minimise slavery from their entire supply line.

5. Key performance indicators

In order to assess the effectiveness of our modern slavery measures we will be reviewing the following key performance indicators:

• Staff training levels;

• Number of slavery incidents reported in the supply chain.

6. Training available to staff

A key part of our slavery and human trafficking strategy is through training. We will ensure all new and existing staff undergo staff training on an annual basis as to the impact of Modern Slavery, signs of abuse within the supply chain, and processes they need to follow to notify and take action.

Changes to this Modern Slavery Statement

We reserve the right to make change to this Privacy Policy. We will update the statement on an annual basis detailing our activities in the past 12 months in tackling Modern Slavery.

Last modification was made June 13, 2018.