• Introduction 

1. 1. Flint Culture is committed to preventing modern slavery, human trafficking, forced or compulsory labour, servitude and exploitation, in line with the Modern Slavery Act 2015, Article 4 of the European Convention on Human Rights and applicable laws in the countries where we operate, We do not tolerate these practices and expect the same standards from everyone working with us. This policy applies to employees, directors, temporary workers, freelancers, consultants, contractors, recruitment agencies and suppliers across our global business, including those involved in creative production and location-based projects.
   2. Modern slavery includes situations where people are forced, coerced or deceived into working against their will, including slavery, servitude, forced labour and human trafficking. We are also committed to preventing child labour and expect appropriate age verification checks to ensure everyone working with us or through our suppliers meets the legal minimum working age.

• Our Standards

1. 1. We believe everyone should be treated fairly, with dignity and respect, and have the freedom to choose where and how they work. All work must be voluntary, and people must be free to leave their employment or assignments with reasonable notice, without fear of threats or pressure. No one should ever have to pay fees to secure work, hand over their passport or identity documents, or face unfair deductions from their pay. Everyone should have clear written terms they understand and receive fair pay and benefits in line with local employment laws. We will not tolerate any form of intimidation, violence, harassment, exploitation or restrictions on personal freedom. We expect the same standards from our suppliers and partners, and ask them to make sure these expectations are understood and upheld by anyone they work with.

• Responsibilities

1. 1. We all have a part to play in making sure people are treated fairly and protected from exploitation. Our senior leadership team is responsible for making sure this policy is supported, put into practice and regularly reviewed. Our HR team helps everyone understand their responsibilities and provides support if concerns are raised. Anyone working with suppliers, freelancers or external partners should take reasonable steps to make sure they share our standards and flag any concerns. Project leads should also consider potential risks when planning and delivering work, particularly when working with production crews, agencies or international partners. We encourage everyone, including our suppliers and partners, to speak up if they see or suspect anything that doesn’t feel right, knowing their concerns will be taken seriously and handled sensitively.

• Risk Assessment 

1. We recognise that the nature of our work means we collaborate with a wide range of people and partners, from freelancers and creative agencies to production crews, event teams and suppliers around the world. We want to make sure everyone involved in delivering our work is treated fairly and works in safe and respectful conditions. We take a practical, proportionate approach to identifying potential risks, particularly when working in different countries, engaging temporary or freelance teams, or using suppliers who bring in other people to support a project. We consider these risks when choosing new suppliers and planning projects, and revisit them if circumstances change. Where we identify a greater risk, we’ll take additional steps to understand how people are recruited, employed and supported, and make sure our partners share our commitment to fair and responsible working practices.

• Supplier & Freelance

Due Diligence

1. When working with new suppliers, freelancers, agencies or partners, we want to feel confident that they share our commitment to treating people fairly and responsibly. We take a practical approach to this, considering who we’re working with, where the work will take place and whether other people or businesses will be involved in delivering it. Depending on the nature of the work, we may ask questions about how people are recruited, paid and supported, particularly when working with production crews, event teams or partners in different countries. We’ll take extra care where there may be greater risks, including checking that suppliers operate legally and understand their responsibilities towards the people they work with. We expect our partners to uphold the same standards, including through their subcontractors, and to raise any concerns openly with us. Where appropriate, we may include these expectations in contractual agreements, require suppliers to follow a code of conduct and reserve the right to carry out checks or audits where concerns arise. Serious breaches may result in termination of the working relationship.
2. If something doesn’t feel right, we’ll ask further questions and, where necessary, involve our HR Director before moving forward. We’ll keep a simple record of any important checks, concerns and decisions, so we can demonstrate that we’re taking our responsibilities seriously.

• Controls During

Client projects

1. When planning and delivering projects, we take time to consider any potential risks to the people involved, particularly when working with production crews, freelancers, event teams or partners in different countries. This means understanding who people are working for, how they’re recruited and paid, and making sure they have fair working conditions and feel able to raise concerns. Where relevant, we’ll also consider working hours, accommodation and other arrangements that could affect people’s wellbeing. If any concerns come up during a project, we’ll take them seriously, involve the right people and agree on the best way forward. We’ll keep a record of any important checks and actions, so we can demonstrate how we’re putting our commitments into practice and share relevant examples with clients when needed.

• Speaking Up & 

Protection From Retaliation

1. We want everyone who works with us, whether they’re part of our team, a freelancer, supplier or partner, to feel comfortable speaking up if something doesn’t seem right. Any concerns about unfair treatment, exploitation or modern slavery can be raised directly with our HR Director (rebecca.taylor@flint-culture.com), or with one of Flint Culture’s founders if that feels more appropriate. We’ll make sure concerns are listened to, taken seriously and handled sensitively and confidentially wherever possible. No one should ever feel worried about being treated unfairly for raising a genuine concern. If someone suspects exploitation or modern slavery, they shouldn’t try to investigate or confront anyone themselves, particularly if doing so could put someone at risk. Instead, we encourage them to speak to us so we can take the right steps to protect and support those involved.

• Responding to 

Concerns

1. If a concern about modern slavery is raised, we’ll take it seriously and respond promptly, with the safety and wellbeing of anyone affected as our priority. We’ll consider each situation carefully, involve the appropriate people within the business and seek external advice or support where needed. If we believe someone is at immediate risk, we’ll contact the relevant authorities. Depending on the circumstances, we may need to speak with a supplier or business partner, ask them to address concerns or reconsider our working relationship with them. We’ll keep an appropriate record of any concerns raised and the actions taken. Our approach will always be practical and proportionate, focused on protecting those affected, addressing the concern responsibly and avoiding any action that could put someone at further risk.

• Awareness &

Training

1. We want everyone who works with Flint Culture to understand our commitment to preventing modern slavery and know what to look out for. This policy will be shared with our team and relevant freelancers and partners, so everyone understands our expectations and knows how to raise concerns. We have historically provided, and continue to provide, compliance training for Flint Culture employees annually, particularly highlighting the warning signs of modern slavery and how to raise concerns. We’ll continue to build awareness through onboarding, team updates and refresher training where appropriate. Our HR Director will help make sure people have the right information and support, particularly those working with suppliers, freelancers or international partners where there may be greater risks. We’ll review our approach regularly to make sure awareness remains relevant and practical for our business.

• Review &

Improvement

1. We want to make sure our approach works in practice and continues to reflect the needs of our people and business. Our HR Director will review this policy annually, looking at any supplier checks carried out, concerns raised, actions taken and opportunities to improve awareness across the team. Any significant findings or improvements will be shared with our founders. We’ll keep appropriate records, respect confidentiality and update the policy sooner if our business, the law or the risks we face change.

• Policy Ownership

& Review

1. Our HR Director is responsible for keeping this policy up to date, with oversight and support from Flint Culture’s founders. We’ll also make sure we meet any relevant legal requirements for reporting on modern slavery.