Modern Slavery and Human Trafficking Statement

By working with us you agree to our terms; being:

1. Introduction

Juicy Media Ltd (“Juicy Media”, “we”, “us”) is committed to protecting and respecting human rights and takes a zero-tolerance approach to modern slavery and human trafficking in all its forms. This statement is made with reference to section 54 of the Modern Slavery Act 2015 and sets out the steps we have taken, and continue to take, to prevent modern slavery and human trafficking in our business and in our supply chains.

Juicy Media’s turnover is below the £36 million threshold at which section 54 requires an annual statement. We publish this statement voluntarily, because our clients, many of them public bodies, expect it of their suppliers and because we hold ourselves to the standard we ask of our own supply chain.

This statement covers Juicy Media Ltd (Company No. 05514688), a private limited company registered in England and Wales and based at Unit 14, Royal Mills, 17 Redhill Street, Ancoats, Manchester M4 5BA. We trade as Juicy Media through our UK website, www.juicymedia.co.uk.

2. Our Organisation Structure, Business and Supply Chains

Structure

  • Juicy Media Ltd is a private limited company with two majority shareholders, who are its directors. The business is led by the Managing Director, supported by the Commercial Director and the Technical Director. We comply with the legislation and governance obligations that apply to a limited company; the obligations we work to are recorded and reviewed in our Legislation Register.

Business

  • We are a full-service digital agency providing web design and development, eCommerce and content-management delivery, digital marketing, managed hosting and related IT consultancy and services to private and public sector clients. Our work commonly includes web development, web design, hosting, migrations, digital design, search marketing and branding. We operate a single integrated business management system certified to ISO 9001:2015 and ISO/IEC 27001:2022.

Supply chains

Our supply chain reflects our operating model as a digital services business. Our direct suppliers are recorded on our Approved Supplier List and fall into three main categories:

  • Technology and hosting: cloud and hosting providers, domain and DNS services, software tooling and subscriptions, and related third-party IT services.
  • Delivery partners and labour: specialist contractors used to scale delivery or to provide specialist capability where required.
  • Hardware and office operations: computers and peripherals, audio-visual equipment and phones, plus general business supplies, travel, printing and other operational services.

3. Our Policies in Relation to Modern Slavery and Human Trafficking

Our approach is anchored in acting ethically and with integrity in all our relationships, and in using reasonable endeavours to prevent modern slavery and human trafficking within our direct operations and our wider sphere of influence. The policies and controls that support this are:

  • Employment and fair working practices: our Employee Handbook and Equal Opportunity Policy set out how we treat the people who work for us. Every new starter is subject to identity, right-to-work and qualification checks under our Staff Onboarding Process and Personnel Security policy.
  • Contingent labour: where agency workers or contractors are needed, we engage them through specified and reliable agencies or directly under written contracts, and they are subject to the same onboarding and vetting as employees.
  • Whistleblowing: our Whistleblowing Policy reflects the Public Interest Disclosure Act 1998. It gives every worker a route to raise concerns about unlawful practice, including suspected modern slavery or human trafficking, and protects them from detriment for doing so. We will report unlawful practices to the relevant authorities where they are identified.
  • Anti-bribery and ethical conduct: our Bribery Act Policy and Corporate Social Responsibility Policy set out our expectations of ethical conduct and responsible sourcing.
  • Supplier management: our Supplier Management Policy and Procedure governs how suppliers are selected, approved, contracted, monitored and exited, and is the framework for the due diligence described in section 4.
  • Governance and assurance: we operate formal policies and controls across the business, with internal audit, a monthly Security Steering Committee and an annual Management Review, supporting a “speak up” culture and clear escalation routes.

4. Due Diligence in Our Business and Supply Chains

We apply proportionate, risk-based due diligence, focused on the areas most relevant to a digital agency and managed hosting provider.

Supplier onboarding and selection

  • efore a new supplier is engaged it is assessed using our Supplier Selection Matrix and, where the nature of the supply warrants it, our Supplier Questionnaire. The questionnaire asks every supplier to confirm that it complies with the Modern Slavery Act 2015 and, where it is required to publish an annual statement, to provide a copy, which is retained with the supplier record.
  • Screening is proportionate to what the supplier provides, with closer attention paid to hosting and technology suppliers, labour agencies and contractors, and outsourced business services.
  • We prefer established suppliers that can demonstrate appropriate governance, legal compliance and responsible business practices.

Contracting and supplier management

  • We set the clear expectation that modern slavery and human trafficking are prohibited in our supply chain.
  • Where appropriate, our contractual and purchasing terms require suppliers and partners to comply with applicable law and to notify us of any suspected or confirmed modern slavery in their operations or supply chains.
  • We manage supplier relationships on an ongoing basis, encouraging transparency and the escalation of concerns.

Verification and monitoring

  • Approved suppliers are recorded on our Approved Supplier List with a criticality rating and are reviewed on a schedule that prioritises the most critical. Questionnaires may be reissued at review to establish whether anything has changed.
  • Any concern identified at review is recorded in our Risk Register and followed through to a conclusion.

Recruitment and labour practices

  • Right-to-work checks and applicant vetting for every new starter.
  • Use of specified and reliable agencies where contingent labour is required.
  • Where a client contract requires it, sponsorship of Security Check (SC) and Developed Vetting (DV) clearances.

Escalation and remediation

If we identify a concern, we assess the risk promptly, require corrective action, and consider suspending or terminating the relationship where the issue cannot be addressed. Where appropriate, we report concerns to the relevant authorities.

5. Risk assessment: where there may be risk, and how we manage it

We recognise that risks can exist across many sectors and that exploitation is not always visible. Based on our operating model, we pay particular attention to:

  • Technology and hosting supply chains: global, multi-tier supply chains can exist behind hardware manufacture and some service delivery.
  • Contractor and agency labour: potential risks include unfair recruitment practices, coercion, withheld documentation or other forms of exploitation.
  • Outsourced business services: risks can exist where services rely on lower-paid or subcontracted labour.

The steps we take to assess and manage these risks include:

  • Using specified and reliable agencies and partners for contractor and agency engagement.
  • Applying risk-based screening to new suppliers and focusing enhanced checks on the higher-risk categories.
  • Reviewing suppliers under our Supplier Management Policy and Procedure and recording any concern in our Risk Register.
  • Maintaining clear routes for concerns to be raised, investigated and acted upon.

6. Effectiveness: How We Measure Performance

We evaluate the effectiveness of our approach using proportionate performance indicators that reflect our size and operating model. These include:

  • Recruitment compliance: completion of right-to-work checks for new starters.
  • Supplier due diligence coverage: the proportion of new suppliers risk-screened at onboarding, with enhanced checks for the higher-risk categories.
  • Contingent labour controls: the proportion of contractor and agency labour engaged through specified and reliable agencies and approved partners.
  • Supplier assurance activity: the number of supplier reviews completed against the Supplier Review Schedule in the period.
  • Reporting and response: the number of concerns raised, including under the Whistleblowing Policy, and the timeliness of their triage and closure.
  • Training completion: completion rates for staff awareness and role-based training (see section 7).

The outputs from these measures inform the continual improvement of our policies, supplier engagement and internal controls through our business management system, and are reviewed through the Security Steering Committee and the annual Management Review.

7. Training and Capacity Building

We are committed to raising awareness of modern slavery among our people. Training and awareness available to them includes:

  • Induction and awareness: guidance on what modern slavery is, how to spot the warning signs, and how to report concerns.
  • Role-based guidance: enhanced awareness and practical guidance for those involved in procurement, supplier management, recruitment and contractor engagement.
  • Refresher updates: periodic internal communications and updates as our controls and supplier monitoring mature.
  • Completion of induction and refresher training is recorded in our Training and Awareness Log.

8. Employment Practices

We are a small business without a dedicated human resources function. We nevertheless vet every applicant, whether based in the United Kingdom or overseas, to confirm their identity, their right to work and the qualifications they hold for the role, and we will continue to improve this process.

9. Governance, Approval and Publication

This statement was approved by the Board of Directors of Juicy Media Ltd on 23 January 2026 and is signed on its behalf by a Director. It was reviewed and re-issued under Juicy Media’s document control on 2 September 2026; the changes made are recorded in the version history at the front of this document.

This statement is published on our UK website at www.juicymedia.co.uk/modern-slavery and is reviewed and updated at least annually. Questions about it should be sent to [email protected].

This statement is supported by the following Juicy Media documents, which are held under our document control: Legislation Register; Supplier Management Policy and Procedure; Supplier Questionnaire; Supplier Selection Matrix; Approved Supplier List; Whistleblowing Policy; Bribery Act Policy; Equal Opportunity Policy; Corporate Social Responsibility Policy; Employee Handbook; Staff Onboarding Process; Personnel Security; Quality Policy; Information Security Policy; Risk Register; Training and Awareness Log.

Approved by the Board of Directors of Juicy Media Ltd on 23 January 2026; reviewed and re-issued 2 September 2026.
Ian Strachan, Managing Director
Updated: 02.09.2026