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Modern Slavery Policy

The purpose of this Modern Slavery Policy is to communicate Effra Digital Ltd’s commitment to delivering a work environment that is free from human trafficking, forced labour and unlawful child labour (collectively “human trafficking and slavery”).  

Modern Slavery Policy Statement 

Human trafficking and slavery are crimes under UK and international law. These crimes exist in countries throughout the world. This policy statement defines Effra’s commitment to ensuring that human trafficking, slavery, forced labour and harmful child labour will never exist within its own business. 

In addition, Effra commits to never knowingly using or procuring unlawful child labour or forced labour in any of the utilities and/or other commodities, products and/or services it provides, nor will it accept commodities, products and/or services from suppliers that employ or utilise child labour or forced labour. 


Human trafficking: the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation. 

Forced labour: all work or service, not voluntarily performed, that is obtained from an individual under the threat of force or penalty. 

Harmful child labour: consists of the employment of children that is economically exploitative, or is likely to be hazardous to, or interfere with, the child’s education, or to be harmful to the child’s health, or physical, mental, spiritual, moral, or social development. 


Effra’s Directors will take appropriate steps to ensure not only its own compliance but also that these requirements are followed by its suppliers, subcontractors and/or business partners (collectively by its “Suppliers”). 

All Suppliers are therefore required to adhere to the following: 

  • Will not use forced or compulsory labour, i.e., any work or service that a worker performs involuntarily, under threat of penalty; 
  • Will ensure that the overall terms of employment are voluntary; 
  • Will comply with the minimum age requirements prescribed by applicable laws 
  • Will compensate its workers with wages and benefits that meet or exceed the legally required minimum and will comply with overtime pay requirements; 
  • Will abide by applicable law concerning the maximum hours of daily labour; 
  • Will not engage in any practice of slavery, servitude, forced labour, compulsory labour and/or human trafficking outside the UK which would constitute an offence if that conduct took place within the UK


Upon request, Suppliers must be able to demonstrate compliance with this Policy to the reasonable satisfaction of Effra. Effra may perform periodic audits on this Policy and Suppliers are expected to fully co-operate with any such audit. 


Any breach of this Policy (including by a Supplier) can be reported (in confidence, if required) by contacting Effra’s two Directors. 


Effra takes any breach of this Policy extremely seriously. 

Suppliers who are found to have or be engaging in human trafficking and slavery or which refuse to co-operate with any audit to verify compliance with this Policy will be liable to have any supply agreement, arrangement or other contract with Effra terminated immediately, without compensation. 

If a Supplier to Effra is found in violation of this policy, Effra will take prompt action which may include terminating any supply agreement, arrangement or other contract with that Supplier (as above). It shall also take such other (remedial) steps as the Anti- Slavery and Human Trafficking Officer shall determine to be necessary to address the violation and seek to prevent its recurrence. 

Policy Management  

The policy applies to all staff within Effra Digital Ltd (the Company), including employees and other workers, such as agency workers, temporary workers and contractors. All staff are expected to put this policy into practice. 

A copy of this policy is distributed to all employees and is made available to other workers on their engagement.  Job seekers and applicants are sent a copy of the policy on request.  In addition, all employees have received briefing on this policy and the induction process for new employees includes a briefing on this policy.  

Any questions about the policy should be directed to the Directors. 

The policy is regularly reviewed and may be amended at any time.  

Effective Date 

This policy is effective from January 2024

Next Review: January 2025 

Claire Collins