Anti-Slavery and Human Trafficking Statement

Introduction from Chief Executive Officer

Slavery and exploitation are real issues that affect too many people in the modern age. At ThinkOn, we take seriously our responsibility in the protection of fundamental human rights and the elimination of modern slavery by ensuring that slavery, human trafficking, and child labour has no place anywhere in our business. We promote a safe and happy workplace where we recruit and celebrate a diverse workforce and our colleagues feel valued as individuals, with equal opportunities. Our Diversity and Belonging Policy also applies to our relationships with third parties and underpins our commitment to building strong and inclusive relationships.

Craig McLellan

 Our approach

As an organisation providing professional services and with a relatively short supply chain, we assess the risk of modern slavery within our business and supply chain to be low. However, we are committed to working ethically and with integrity and we consider modern slavery to be a fundamental issue. So we are committed to ensuring that it does not take place anywhere within our business, including our international offices, or our supply chain.

We have a zero-tolerance policy towards modern slavery, a crime and violation of fundamental human rights: This includes any form of slavery, servitude and forced or compulsory labour.

Our Policy highlights our commitments in our dealings and relationships, including our own recruitment process and our supply chain.

Our Policy also sets out steps that our staff can take if they are concerned about modern slavery. We maintain a Whistleblowing Policy and other sustainable business policies that ensure issues should not arise but if they do, any concerns raised can be dealt with appropriately.

Supplier due diligence

We expect all our contractors, suppliers and other business partners to adopt the same high standard as we do to prevent modern slavery, by ensuring all employees and workers are treated with dignity and respect in a fair and ethical environment.

Our procurement process includes vetting of all potential suppliers, with responses being evaluated on the basis of supplier policies and controls. Suppliers will be categorised according to the level of risk posed and an assessment will be made as to whether a plan of action is required to satisfy any gaps. We expect our suppliers to adopt the same principles when contracting with their own suppliers and plan to make this a requirement.

All suppliers will be required to sign a declaration confirming their compliance with the Act and our Policy and to contract on terms which ensure that we can check their adherence to these principles and where appropriate take corrective action.

We intend to implement a six-monthly audit programme for major suppliers to ensure continued compliance with our obligations under the Act.

Recruitment and work culture at ThinkOn

We are dedicated to maintaining a fair and ethical workplace for all our staff.

We ensure compliance with all applicable employment legislation relating to employee recruitment and terms and conditions, including right to work evidence and that no ThinkOn staff are paid less than the living wage. Our Grievance and Whistleblowing Policies enable concerns to be raised and resolved. Those can include any concerns about supplier practices.

Our Diversity and Belonging Policy and procedures promote diversity, establishing mutual respect as a core value in the office and deal with discrimination, harassment and bullying.


It is important to us that our colleagues are aware of the issues surrounding modern slavery and support the firm’s values. We therefore intend to offer a training programme for existing employees and consultants to reinforce our zero-tolerance policy and the steps to be taken in the event of any concerns.


Our Compliance Team will be responsible for checking and testing the success of our commitments and will work with our Human Resources Team and other specialisms to ensure we meet these expectations.

This is our Anti-Slavery and Human Trafficking Statement pursuant to the UK’s Modern Slavery Act 2015, and applies to the financial year ending 31 December 2023.