Boldspace – Modern Slavery and Human Trafficking Statement


This Modern Slavery and Human Trafficking Statement is a response to Section 54(1), Part 6 of the Modern Slavery Act 2015 and relates to actions and activities for the financial year ending 31 March 2021.

Boldspace Group Limited (‘the Company’, ‘we’, ‘us’ or ‘our’) is committed to preventing slavery and human trafficking
violations in its own operations, its supply chain, and its products. We have zero-tolerance towards slavery and require our supply chain to comply with our values.

Organisational structure

Boldspace Group Limited has business operations in the United Kingdom.

We operate in the advertising, marketing and communications sector. The nature of our supply chains is as follows: we work with a number of direct suppliers, who provide us with goods, such as equipment for our premises and services, such as outsourced business processes, IT software and services.

For more information about the Company, please visit our website:


We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.

These include the following:

+ Recruitment and selection policy – Any recruitment shortlist must never be fewer than two people for any individual role and should ideally be four. At least one person on the shortlist must be from a BAME background or have a clear trait that would widen the diversity of the Boldspace team.

+ Whistleblowing policy – Having an open culture at Boldspace is very important to us, which is why if malpractice occurs it should be handled with honest and effective communication. The whistleblowing policy provides guidelines to all team members, casual, temporary agency staff, freelancers, trainees, home workers and contractors, who feel they need to raise certain issues, in confidence. It outlines that if they raise a genuine concern, their position will not be at risk. Provided they are acting in the public interest it does not matter whether or not their concern proves to be well founded.

+ Staff code of conduct – It outlines our approach to transparency, anti-corruption and valuing both diversity and
dignity at work. We make sure our suppliers are aware of our policies and adhere to the same standards.

Due Diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring in our supply chains, we have adopted internal supplier audits.

Our due diligence procedures aim to:

+ Identify and action potential risks in our business and supply chains.
+ Monitor potential risks in our business and supply chains
+ Reduce the risk of slavery and human trafficking occurring in our business and supply chains.
+ Provide protection for whistleblowers.

Risk and compliance

The Company has evaluated the nature and extent of its exposure to the risk of slavery and human trafficking occurring in its UK supply chain through evaluating the slavery and human trafficking risks of each new supplier.

We do not consider that we operate in a high-risk environment because the majority of our supply chain is based in the UK and in low-risk industries, such as internet software and services.

We do not tolerate slavery and human trafficking in our supply chains. Where there is evidence of failure to comply with our policies and procedures by any of our suppliers, we will require that supplier to remedy the non-compliance or face dismissal.


We cannot say with any certainty how effective the steps we are taking have been in ensuring that slavery and human trafficking is not taking place in our business and supply chains. As part of our work for the next financial year, we will be considering how best to monitor the effectiveness of the actions taken.

The statement was approved by the board of directors.

Mike Robb, Director, Boldspace Group Limited

Date: 16 December 2021