Modern Slavery and Human Trafficking Statement

Introduction
The following statement is made in acknowledgement of section 54(1) part 6 of the Modern Slavery Act 2015 and sets out the steps that Black Bear Creative are taking to ensure that slavery and human trafficking are not taking place in in any part of our business activities. Including our supply chains.

It should be noted however that the size of our business operations in terms of turnover is less than £36 million per annum and therefore we are not bound by law to the terms of section 45 (1) part 6 of the Modern Slavery Act 2015, however notwithstanding this, as an organisation
that is committed to ethical business and employment practices and policies, we believe we have a moral responsibility to prevent any potential abuses from occurring in our supply chains, or amongst our employees or workers.

Black Bear Creative Ltd is committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of slavery and human trafficking taking place within the business or our supply chain.

Our Structure
Black Bear Creative Ltd is a limited company Incorporation Number 10734266. There are no other associated or subsidiary companies. Black Bear Creative Ltd is an award-winning marketing and creative team that delivers creative solutions. Black Bear Creative offer a range of services to deliver flexible solutions including Creative, Copy, Design, Photography, Integrated Campaign, Script Writing, Storyboard Development, Media Planning, Strategy, Campaign Identify, Film Production, Cash Direct Mail, Data Analysis, Community Fundraising Consultancy You can be sure that the combination of our team’s imagination and experience in delivering creative solutions is a successful one. We will target and deliver the right message, at the right time, to the right person, with impactful and engaging creative.

Our company registered office is:
Black Bear Creative Ltd
Abacus House
14-18 Forest Road
Loughton
Essex
IG10 1DX

Responsibility for ensuring ethical business practice and employment practice underpins all our activities including tackling modern slavery resides with the Director, Timothy Wickens. BLACK BEAR CREATIVE LTD incorporated and registered in England and Wales with company number 10734266 whose registered office is at Abacus House, 14-18 Forest Road, Loughton, Essex, IG10 1DX. Registered VAT number 269 4609 62.

Our Supply Chains
Our diverse range of activities has resulted in a supply chain that ranges from large corporate enterprises to small family run businesses and independent free-lance consultants. We expect our contractors, suppliers, and other business partners to uphold high standards in all
business practices and to share our zero-tolerance approach to slavery and human trafficking. We expect all suppliers to comply with all relevant laws of the country in which they operate. We select our suppliers and business partners carefully, and where possible, conduct
due diligence on them, so that we are comfortable that we are doing business with trusted partners, and known parties who effect business in full compliance with local law and best practice.

We work closely in partnership with two multi-award-winning print-suppliers the Paragon Group Ltd and Pure Print Group Ltd, both of whom have been recognised within the Print Industry as market leaders. Both organisations actively demonstrate their commitment to ensuring ethical business practice throughout their supply chains and have published their Anti-Slavery Policies on their websites together with their Modern Slavery and Human Trafficking Annual Statements.

Black Bear Creative Ltd expects all of its suppliers, contractors and service providers to act ethically and with integrity and to have in place effective systems, safeguards and controls to ensure modern slavery is not taking place anywhere in their own business or in their supply
chains. Black Bear Creative operates and maintains preferred supplier lists. We encourage all our suppliers to comply with our policies, often by raising awareness of our policies as part of our procurement tender processes and / or we expect that they will have similar policies in
place.

Before any new supplier, contractor or service provider is approved, Black Bear Creative Ltd carries out appropriate due diligence on the supplier including an on-line search to ensure that an organisation has not been convicted of any offences, including, but not limited to, offences relating to modern slavery whether through human trafficking, slavery, child labour or otherwise. As part of our contracting processes, all UK suppliers are required to sign the Black Bear Creative Supplier Code of Conduct which includes prohibitions against the use of staff sourced from forced, compulsory or trafficked labour, and anyone held in slavery or servitude.

Our Policies on Slavery and Human Trafficking
To help prevent modern slavery or human trafficking in our business and supply chains, we have adopted an Anti-Slavery Policy. Our Anti-Slavery Policy reflects our commitment to acting ethically and with integrity, and to implementing effective systems and control to help
ensure slavery and human trafficking is not taking place in our business and supply chains.

We will monitor and update this Anti-Slavery Policy as necessary going forward. We operate several internal policies to ensure that we are conducting businesses in an ethical and transparent manner, these policies include:-

Anti-slavery Policy: This Policy sets out the company’s stance on modern slavery and explains how employees can identify any instances of this and how to report concerns. Employee Code of Conduct: The Code of Conduct explains the way we behave as an organisation and details the core values and duties that we expect all stakeholders and employees to adhere to. All employees are responsible for reading, understanding and complying with the principles as outlined in the Code of Conduct. A copy of the Code of  BLACK BEAR CREATIVE LTD incorporated and registered in England and Wales with company number 10734266 whose registered office is at Abacus House, 14-18 Forest Road, Loughton, Essex, IG10 1DX. Registered VAT number 269 4609 62. Conduct is issued to all new employees for signature during either their on-boarding into the company or induction. The Code of Conduct is also included in the Employee Handbook.

Reporting Concerns: Employees are encouraged and asked to report genuine concerns that they may have over possible violations to the Code of Conduct or any other concerns that they feel are unlawful or unethical.

Recruitment Policy: We have recruitment processes in place to ensure that where we appoint a third party to assist with recruitment; they do not charge recruitment fees to the individual being considered for employment. We undertake verification of all individuals, as required by UK
legislation, prior to appointment and in certain roles, which includes DBS and other security checks.

Pay Policy: Black Bear Creative Ltd adheres to the standards of the National Living Wage legislation and Minimum Wage legislation in the UK and relevant local regulation in each market within which we operate. This is reviewed on an annual basis.

Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and its supply chains, we provide training for our employees in order that we can identify potential signs of modern slavery; human trafficking or child grooming and sexual
exploitation, and, if necessary, report them without fear of penalty.

Timothy Wickens
Chief Executive Officer
30th April 2018

Appendix 1
Anti- Slavery and Human Trafficking Policy Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. Black Bear Creative Ltd has a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

We also expect the same high standards from all of our suppliers, contractors and other business partners and, as part of our contracting processes, are included specific prohibitions against the use of modern slavery, and we expect that our suppliers will in turn hold their own suppliers to the same standards. Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Back Bear Creative accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited; that they are safe; and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.

This policy applies to all individuals working for or on behalf of Black Bear Creative Ltd in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the policy
Tim Wickens, CEO has responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible
for investigating allegations of modern slavery in the Company’s business or supply chains

Compliance
The prevention, detection and reporting of modern slavery in any part of Black Bear Creative Ltd’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. You are required to avoid any
activity that might lead to a breach of this policy. If you believe or suspect a breach of or conflict with this policy has occurred or may occur, you must notify your line manager or report it in accordance with Black Bear Creative’s Disclosures in the Public Interest Policy.

BLACK BEAR CREATIVE LTD incorporated and registered in England and Wales with company number 10734266 whose registered office is at Abacus House, 14-18 Forest Road, Loughton, Essex, IG10 1DX. Registered VAT number 269 4609 62. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of our business or supply chains as soon as possible. If you are unsure about whether a
particular act, the treatment of workers or their working conditions within any of our supply chains constitutes any of the various forms of modern slavery, please raise it with your line manager. You can also contact the government’s Modern Slavery Helpline on 0800 0121 700
for further information and guidance on modern slavery.

Black Bear Creative aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of
reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.

Training and communication
Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, will be provided to staff as necessary, so that they know how to identify exploitation and modern slavery and how to report suspected cases.  The Company’s zero tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.

Breach of the policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. Black Bear Creative Ltd may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.

Timothy